Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
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Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
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In a transfer pricing dispute concerning the software development services segment, the ITAT held that the Transfer Pricing Officer had not dealt with the five comparables remitted for reconsideration, and that the later DRP consideration did not cure the failure to follow the earlier appellate direction in time. The defect was treated as an irregularity requiring correction, not as a basis to annul the assessment. The Assessing Officer was therefore directed to exclude Acropetal Technologies, E-Zest Solutions, E-Infochips, ICRA Techno Analytics and Persistent Systems and recompute the arm's length price adjustment; the assessment was otherwise left undisturbed.
In a transfer pricing dispute concerning the software development services segment, the ITAT held that the Transfer Pricing Officer had not dealt with the five comparables remitted for reconsideration, and that the later DRP consideration did not cure the failure to follow the earlier appellate direction in time. The defect was treated as an irregularity requiring correction, not as a basis to annul the assessment. The Assessing Officer was therefore directed to exclude Acropetal Technologies, E-Zest Solutions, E-Infochips, ICRA Techno Analytics and Persistent Systems and recompute the arm's length price adjustment; the assessment was otherwise left undisturbed.
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