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...
Failure to record reasons in an administrative decision was held to violate principles of natural justice because the competent bodies did not disclose why the petitioner's submissions or parity claims were rejected; administrative orders must state reasons objectively and cannot be supplemented after the fact. In view of the absence of adequate reasoning and apparent non application of mind, the matter is remitted to the Review Committee for fresh consideration and for passing a reasoned order addressing the contentions and parity issues within a reasonable time.
Failure to record reasons in an administrative decision was held to violate principles of natural justice because the competent bodies did not disclose why the petitioner's submissions or parity claims were rejected; administrative orders must state reasons objectively and cannot be supplemented after the fact. In view of the absence of adequate reasoning and apparent non application of mind, the matter is remitted to the Review Committee for fresh consideration and for passing a reasoned order addressing the contentions and parity issues within a reasonable time.
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