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...
Supreme Court suo motu orders excluded 15 March 2020-28 February 2022 from limitation computation, so any balance limitation remaining on 15 March 2020 must be added to 1 March 2022 and becomes available from that date. Applying that principle to Section 95 applications where limitation expired during the excluded period, the balance period was calculated as of 15 March 2020 and added to 1 March 2022; applications falling within the recalculated periods are not time barred. Orders dismissing those applications as barred were set aside and the matters remitted for fresh consideration.
Supreme Court suo motu orders excluded 15 March 2020-28 February 2022 from limitation computation, so any balance limitation remaining on 15 March 2020 must be added to 1 March 2022 and becomes available from that date. Applying that principle to Section 95 applications where limitation expired during the excluded period, the balance period was calculated as of 15 March 2020 and added to 1 March 2022; applications falling within the recalculated periods are not time barred. Orders dismissing those applications as barred were set aside and the matters remitted for fresh consideration.
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