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...
Non-compliance with a remand direction requiring completion of penalty proceedings within 12 weeks rendered the reinitiated proceedings unsustainable. The record showed that no final order under the penalty provision had been passed within the stipulated period and no extension of time had been sought. Mere issuance of show-cause notices did not amount to compliance, especially where repeated requests for a hearing had not been effectively addressed. On that ground, the show-cause notices issued in continuation of the remand were quashed.
Non-compliance with a remand direction requiring completion of penalty proceedings within 12 weeks rendered the reinitiated proceedings unsustainable. The record showed that no final order under the penalty provision had been passed within the stipulated period and no extension of time had been sought. Mere issuance of show-cause notices did not amount to compliance, especially where repeated requests for a hearing had not been effectively addressed. On that ground, the show-cause notices issued in continuation of the remand were quashed.
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