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...
Belated filing of Form 10-IC was treated as a procedural lapse where the assessee had clearly opted for the concessional regime under section 115BAA by computing tax accordingly in the return and the form was on record when the return was processed. As the form had not been withdrawn, rejected or invalidated, and eligibility for the lower rate was undisputed, the delay did not justify denial of the statutory benefit. Tax was directed to be recomputed at the concessional rate under section 115BAA.
Belated filing of Form 10-IC was treated as a procedural lapse where the assessee had clearly opted for the concessional regime under section 115BAA by computing tax accordingly in the return and the form was on record when the return was processed. As the form had not been withdrawn, rejected or invalidated, and eligibility for the lower rate was undisputed, the delay did not justify denial of the statutory benefit. Tax was directed to be recomputed at the concessional rate under section 115BAA.
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