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 rectification order was set aside for breach of natural justice because it had been passed without affording the petitioner a hearing and without considering its submissions and documents. The Court treated this procedural illegality as the ative defect and directed de novo consideration by the designated authority. The authority was permitted to issue a fresh show cause notice, grant personal hearing, and pass a reasoned and speaking order, with all rival contentions left open for fresh adjudication.
The rectification order was set aside for breach of natural justice because it had been passed without affording the petitioner a hearing and without considering its submissions and documents. The Court treated this procedural illegality as the ative defect and directed de novo consideration by the designated authority. The authority was permitted to issue a fresh show cause notice, grant personal hearing, and pass a reasoned and speaking order, with all rival contentions left open for fresh adjudication.
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