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...
Non-supply of relied-upon documents with the show-cause notice and refusal to permit requested cross-examination were held to breach the principles of natural justice and the right to a fair hearing; the impugned order was quashed and the matter remanded for a fresh inquiry from the stage of issuance of the show-cause notice. The respondents are directed to supply all relied-upon documents with a list of RUDs, permit cross-examination where requested, and complete the inquiry in accordance with law within three months.
Non-supply of relied-upon documents with the show-cause notice and refusal to permit requested cross-examination were held to breach the principles of natural justice and the right to a fair hearing; the impugned order was quashed and the matter remanded for a fresh inquiry from the stage of issuance of the show-cause notice. The respondents are directed to supply all relied-upon documents with a list of RUDs, permit cross-examination where requested, and complete the inquiry in accordance with law within three months.
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