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...
Availability of an efficacious statutory appeal against assessment orders bars resort to writ jurisdiction; failure to disclose that remedy and a misleading claim of no alternate efficacious remedy warranted dismissal, and the petitioner was granted liberty to pursue the statutory appeal. Disputed factual questions-specifically service of notice by electronic means and infringement of natural justice-are unsuitable for summary resolution in writ proceedings and do not justify bypassing the appellate scheme. All substantive contentions remain open for determination before the appellate forum.
Availability of an efficacious statutory appeal against assessment orders bars resort to writ jurisdiction; failure to disclose that remedy and a misleading claim of no alternate efficacious remedy warranted dismissal, and the petitioner was granted liberty to pursue the statutory appeal. Disputed factual questions-specifically service of notice by electronic means and infringement of natural justice-are unsuitable for summary resolution in writ proceedings and do not justify bypassing the appellate scheme. All substantive contentions remain open for determination before the appellate forum.
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