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 Tribunal reiterated that the amendment enhancing the tax rate under section 115BBE is substantive and applies prospectively. Income surrendered in a survey conducted before the amendment therefore remained taxable only at the rate then in force, not at the enhanced rate introduced later. Relying on binding jurisdictional precedent, it held that where the survey occurred on 22.09.2016, the Revenue could not apply the amended special rate to the surrendered income. The impugned addition was directed to be deleted.
The Tribunal reiterated that the amendment enhancing the tax rate under section 115BBE is substantive and applies prospectively. Income surrendered in a survey conducted before the amendment therefore remained taxable only at the rate then in force, not at the enhanced rate introduced later. Relying on binding jurisdictional precedent, it held that where the survey occurred on 22.09.2016, the Revenue could not apply the amended special rate to the surrendered income. The impugned addition was directed to be deleted.
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