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...
Interim relief seeking return of re quantified proceeds was refused because an interlocutory order cannot grant final relief and releasing the funds would risk dissipation that could render the respondent's cross appeal infructuous; the reduced quantification did not map to identifiable discrete assets, creating prima facie irreparable prejudice, so the interim application was dismissed while preserving substantive rights in the main appeal. To avoid multiplicity and balance equities, all appeals arising from the adjudicatory order are to be consolidated and heard expeditiously with prescribed pleading timelines and case management steps.
Interim relief seeking return of re quantified proceeds was refused because an interlocutory order cannot grant final relief and releasing the funds would risk dissipation that could render the respondent's cross appeal infructuous; the reduced quantification did not map to identifiable discrete assets, creating prima facie irreparable prejudice, so the interim application was dismissed while preserving substantive rights in the main appeal. To avoid multiplicity and balance equities, all appeals arising from the adjudicatory order are to be consolidated and heard expeditiously with prescribed pleading timelines and case management steps.
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