Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Pre-existing disputes and timing of default were decisive: contemporaneous communications and invoices showed plausible disputes on invoices, taxes and reconciliations requiring investigation, and applying the Mobilox and Sabarmati plausibility standard the insolvency petition was not maintainable on that ground. Separately, the contract stipulated default accrual only after a 365-day period from amount becoming due, making the demand notice prima facie premature as no default had occurred on the notice date. The adjudicating authority's rejection of the petition was therefore upheld.
Pre-existing disputes and timing of default were decisive: contemporaneous communications and invoices showed plausible disputes on invoices, taxes and reconciliations requiring investigation, and applying the Mobilox and Sabarmati plausibility standard the insolvency petition was not maintainable on that ground. Separately, the contract stipulated default accrual only after a 365-day period from amount becoming due, making the demand notice prima facie premature as no default had occurred on the notice date. The adjudicating authority's rejection of the petition was therefore upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
