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...
Synchronized trading used to create artificial volumes and manipulate share prices justified estimation of commission income at 5%. The Tribunal held that once the assessee's involvement in price rigging and SEBI debarment was accepted, there was no basis to treat the activity as normal brokerage or to reduce the Assessing Officer's estimate to 1%. The Commissioner (Appeals) was therefore set aside and the higher commission addition was restored.
Synchronized trading used to create artificial volumes and manipulate share prices justified estimation of commission income at 5%. The Tribunal held that once the assessee's involvement in price rigging and SEBI debarment was accepted, there was no basis to treat the activity as normal brokerage or to reduce the Assessing Officer's estimate to 1%. The Commissioner (Appeals) was therefore set aside and the higher commission addition was restored.
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