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...
Initiation of contempt proceedings by issuance of a show cause notice does not ordinarily create an appealable right because it does not adjudicate substantial rights; accordingly the appellate forum declined to entertain the appeal against the notice but granted liberty to the respondent to file a reply to the notice before the tribunal. An interim disclosure direction concerning transactions was treated as superseded and its subject matter subsumed in a pending substantive appeal, so the separate appeal on that disclosure was dismissed as unnecessary and related pending applications were disposed of.
Initiation of contempt proceedings by issuance of a show cause notice does not ordinarily create an appealable right because it does not adjudicate substantial rights; accordingly the appellate forum declined to entertain the appeal against the notice but granted liberty to the respondent to file a reply to the notice before the tribunal. An interim disclosure direction concerning transactions was treated as superseded and its subject matter subsumed in a pending substantive appeal, so the separate appeal on that disclosure was dismissed as unnecessary and related pending applications were disposed of.
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