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...
Finality of higher-court orders prevents a lower court from revisiting or altering the operative effect of an earlier superior-court relief so as to prejudice beneficiaries; the appellants' promotions implemented pursuant to the earlier order were protected and the appeal was allowed limitedly to safeguard their career progression. Persons not impleaded in earlier proceedings but asserting prejudice from those decisions are not without remedy: the Court reaffirmed precedents permitting limited review or fresh proceedings before competent tribunals and granted intervenors liberty to pursue appropriate fora to seek individual relief; connected applications were disposed accordingly.
Finality of higher-court orders prevents a lower court from revisiting or altering the operative effect of an earlier superior-court relief so as to prejudice beneficiaries; the appellants' promotions implemented pursuant to the earlier order were protected and the appeal was allowed limitedly to safeguard their career progression. Persons not impleaded in earlier proceedings but asserting prejudice from those decisions are not without remedy: the Court reaffirmed precedents permitting limited review or fresh proceedings before competent tribunals and granted intervenors liberty to pursue appropriate fora to seek individual relief; connected applications were disposed accordingly.
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