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...
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Reassessment is invalid where the Assessing Officer furnishes reopening reasons but fails to dispose of the assessee's objections by a speaking order before completing reassessment. Applying the procedure in GKN Driveshafts and the jurisdictional High Court ruling in Hewlett Packard Financial Services, the Tribunal held that such disposal is mandatory. As the later objections challenging the reopening were never addressed, the notice under section 148 and the reassessment order under sections 143 read with 147 could not survive and were set aside.
Reassessment is invalid where the Assessing Officer furnishes reopening reasons but fails to dispose of the assessee's objections by a speaking order before completing reassessment. Applying the procedure in GKN Driveshafts and the jurisdictional High Court ruling in Hewlett Packard Financial Services, the Tribunal held that such disposal is mandatory. As the later objections challenging the reopening were never addressed, the notice under section 148 and the reassessment order under sections 143 read with 147 could not survive and were set aside.
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