Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
The HC held that rejection of the statutory appeal on jurisdictional grounds was a departmental mistake where the office lacked a system to transmit the appeal to the correct appellate authority. Treating the defect as procedural rather than substantive, the Court set aside the impugned appellate order without examining the merits of the underlying dispute. The appeal was restored and directed to be transmitted to the competent appellate authority for consideration in accordance with law.
The HC held that rejection of the statutory appeal on jurisdictional grounds was a departmental mistake where the office lacked a system to transmit the appeal to the correct appellate authority. Treating the defect as procedural rather than substantive, the Court set aside the impugned appellate order without examining the merits of the underlying dispute. The appeal was restored and directed to be transmitted to the competent appellate authority for consideration in accordance with law.
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