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...
A pending rectification application must be decided before a statutory appeal is dismissed, where the rectification could affect the adjudication order under challenge. The High Court held that the appellate authority should not have rejected the appeal while rectification proceedings were still pending, and the appellate order was therefore unsustainable. It set aside the dismissal of the appeal and directed that the rectification application be decided first, after affording personal hearing and by a reasoned order, within the time fixed by the Court.
A pending rectification application must be decided before a statutory appeal is dismissed, where the rectification could affect the adjudication order under challenge. The High Court held that the appellate authority should not have rejected the appeal while rectification proceedings were still pending, and the appellate order was therefore unsustainable. It set aside the dismissal of the appeal and directed that the rectification application be decided first, after affording personal hearing and by a reasoned order, within the time fixed by the Court.
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