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 HC held that the Tribunal could not dismiss the assessee's appeal without adjudicating the substantive grounds on merits. Reliance on the time taken by the CIT(A) to dispose of the appeal was an irrelevant consideration, especially in light of the disruption and backlog caused during the Covid-19 period. Because the Tribunal decided the matter on a basis unrelated to the merits of the controversy, its order was unsustainable. The order was set aside and the matter was remanded to the Tribunal for fresh disposal on merits after consideration of all grounds raised by the assessee.
The HC held that the Tribunal could not dismiss the assessee's appeal without adjudicating the substantive grounds on merits. Reliance on the time taken by the CIT(A) to dispose of the appeal was an irrelevant consideration, especially in light of the disruption and backlog caused during the Covid-19 period. Because the Tribunal decided the matter on a basis unrelated to the merits of the controversy, its order was unsustainable. The order was set aside and the matter was remanded to the Tribunal for fresh disposal on merits after consideration of all grounds raised by the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
