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...
After a search under section 132 in the assessee's case, the ITAT held that the Assessing Officer could not continue with a normal scrutiny assessment under section 143(3) and had to proceed under the special post-search statutory route. Because the Revenue did not dislodge this jurisdictional defect, the Tribunal found an invalid assumption of jurisdiction and quashed the assessment framed under section 143(3). The grounds challenging the additions on merits were therefore rendered academic.
After a search under section 132 in the assessee's case, the ITAT held that the Assessing Officer could not continue with a normal scrutiny assessment under section 143(3) and had to proceed under the special post-search statutory route. Because the Revenue did not dislodge this jurisdictional defect, the Tribunal found an invalid assumption of jurisdiction and quashed the assessment framed under section 143(3). The grounds challenging the additions on merits were therefore rendered academic.
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