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...
Payment received under an employer's ERS/VRS scheme, being ex gratia compensation on cessation of employment and not shown to arise from any enforceable obligation for termination, was held not taxable as profits in lieu of salary under section 17(3)(i). Following its earlier decision on similar facts, the Tribunal found no contrary material from the Revenue and held that the addition sustained by the appellate authority was unsustainable. The addition was directed to be deleted.
Payment received under an employer's ERS/VRS scheme, being ex gratia compensation on cessation of employment and not shown to arise from any enforceable obligation for termination, was held not taxable as profits in lieu of salary under section 17(3)(i). Following its earlier decision on similar facts, the Tribunal found no contrary material from the Revenue and held that the addition sustained by the appellate authority was unsustainable. The addition was directed to be deleted.
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