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...
Best judgment assessment in a civil contract business must rest on a fair estimate with nexus to available material; a flat 15 per cent profit rate was found arbitrary on the facts, and business income was directed to be recomputed at 7 per cent of turnover. The Tribunal also held that claims for Chapter VI-A deductions and credits for TDS and self-assessment tax could not be decided on the existing record because supporting documents and reconciliations were incomplete, so the matter was remitted for verification and grant of eligible relief in accordance with law.
Best judgment assessment in a civil contract business must rest on a fair estimate with nexus to available material; a flat 15 per cent profit rate was found arbitrary on the facts, and business income was directed to be recomputed at 7 per cent of turnover. The Tribunal also held that claims for Chapter VI-A deductions and credits for TDS and self-assessment tax could not be decided on the existing record because supporting documents and reconciliations were incomplete, so the matter was remitted for verification and grant of eligible relief in accordance with law.
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