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...
Garnishee notice directing provisional attachment of the petitioner's bank account was ordered withdrawn because the revenue authority failed to consider the petitioner's prior submissions and offered documents; immediate freezing was unjustified absent findings of deliberate evasion. The petitioner must submit requisite documents within ten days, and the department must examine them, invite clarification or hearing if needed, and decide the recovery question on merits within one month of submission; all contentions remain open pending that reconsideration.
Garnishee notice directing provisional attachment of the petitioner's bank account was ordered withdrawn because the revenue authority failed to consider the petitioner's prior submissions and offered documents; immediate freezing was unjustified absent findings of deliberate evasion. The petitioner must submit requisite documents within ten days, and the department must examine them, invite clarification or hearing if needed, and decide the recovery question on merits within one month of submission; all contentions remain open pending that reconsideration.
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