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...
Validity of a notice under section 143(2) was contested on limitation and service grounds: the revised/rectified return filed later was held to relate back to the original return date, so the six month limitation for issuing a notice ran from the original filing and expired before the notice dated 22.09.2019; additionally no notice was served within the statutory period due to change of address/name/email, and because service of the section 143(2) notice is mandatory, the assessment was held void and quashed.
Validity of a notice under section 143(2) was contested on limitation and service grounds: the revised/rectified return filed later was held to relate back to the original return date, so the six month limitation for issuing a notice ran from the original filing and expired before the notice dated 22.09.2019; additionally no notice was served within the statutory period due to change of address/name/email, and because service of the section 143(2) notice is mandatory, the assessment was held void and quashed.
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