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 High Court held that a Dispute Resolution Panel direction was binding and could not be ignored by the Assessing Officer. Because no departmental appeal had been filed on the earlier years' issue, the addition made under section 40(a)(i) was contrary to the DRP's clear mandate and could not be sustained. The Court therefore exercised writ jurisdiction to quash the demand, including interest, relatable to that addition, despite the availability of an alternate appellate remedy. The remaining transfer pricing adjustment was left open to challenge in the ordinary appeal, with protection against limitation if filed within the time granted.
A High Court held that a Dispute Resolution Panel direction was binding and could not be ignored by the Assessing Officer. Because no departmental appeal had been filed on the earlier years' issue, the addition made under section 40(a)(i) was contrary to the DRP's clear mandate and could not be sustained. The Court therefore exercised writ jurisdiction to quash the demand, including interest, relatable to that addition, despite the availability of an alternate appellate remedy. The remaining transfer pricing adjustment was left open to challenge in the ordinary appeal, with protection against limitation if filed within the time granted.
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