Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Eligibility under the Direct Tax Vivad Se Vishwas Scheme, 2024 turns on whether a qualifying appeal or proceeding was pending on the specified date of 22.07.2024. The Court read the scheme and removal of difficulties order to cover only cases where the order appealed from existed before that date, the appeal period was still open on that date, and the appeal was filed within time without any condonation request. Because the Tribunal had already decided the matter, no appeal under section 260A was pending, limitation had expired before the specified date, and the later rectification application was also time-barred, the assessee was held ineligible for the scheme.
Eligibility under the Direct Tax Vivad Se Vishwas Scheme, 2024 turns on whether a qualifying appeal or proceeding was pending on the specified date of 22.07.2024. The Court read the scheme and removal of difficulties order to cover only cases where the order appealed from existed before that date, the appeal period was still open on that date, and the appeal was filed within time without any condonation request. Because the Tribunal had already decided the matter, no appeal under section 260A was pending, limitation had expired before the specified date, and the later rectification application was also time-barred, the assessee was held ineligible for the scheme.
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