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...
On identical facts, the ITAT applied the principle of consistency and upheld assessment of only 1% commission on gross bank transactions, rejecting a broader addition. The Tribunal noted that in the preceding year the Assessing Officer had treated the assessee as a consignment sales agent for Khal Binola and taxed only commission income, and that tax deduction under section 194H supported the view that the bank deposits represented consignment sale proceeds on behalf of principals. Following Radhasoami Satsang and Excel Industries, the Tribunal sustained the addition only to that limited extent and deleted the balance.
On identical facts, the ITAT applied the principle of consistency and upheld assessment of only 1% commission on gross bank transactions, rejecting a broader addition. The Tribunal noted that in the preceding year the Assessing Officer had treated the assessee as a consignment sales agent for Khal Binola and taxed only commission income, and that tax deduction under section 194H supported the view that the bank deposits represented consignment sale proceeds on behalf of principals. Following Radhasoami Satsang and Excel Industries, the Tribunal sustained the addition only to that limited extent and deleted the balance.
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