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...
The Appellate Tribunal held that an adjudicating authority cannot sustain directions issued in a cryptic order that merely reproduces rival submissions without findings on facts or law. Because the impugned order gave no reasons for allowing the application and did not show judicial application of mind, it was treated as a non-speaking order incapable of legal sustenance. The order was set aside and the matter remanded for fresh consideration, with directions to hear both parties and pass a reasoned decision in accordance with law.
The Appellate Tribunal held that an adjudicating authority cannot sustain directions issued in a cryptic order that merely reproduces rival submissions without findings on facts or law. Because the impugned order gave no reasons for allowing the application and did not show judicial application of mind, it was treated as a non-speaking order incapable of legal sustenance. The order was set aside and the matter remanded for fresh consideration, with directions to hear both parties and pass a reasoned decision in accordance with law.
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