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...
Indexation on a capital asset received in amalgamation was held to run from FY 2008-09 because the township had already been constructed and let out by the amalgamating company, with rental income taxed from that year; the tax-neutral transfer under the scheme did not shift the holding period to the later amalgamation order or occupancy certificate. The Tribunal also upheld the claimed short-term capital loss on sale of AIF units to a subsidiary, finding both acquisition and sale valuations followed the NAV method, the fall in value was explained by decline in underlying investments, and a related-party sale is not a colourable device without evidence of tax avoidance. Both revenue appeals were dismissed.
Indexation on a capital asset received in amalgamation was held to run from FY 2008-09 because the township had already been constructed and let out by the amalgamating company, with rental income taxed from that year; the tax-neutral transfer under the scheme did not shift the holding period to the later amalgamation order or occupancy certificate. The Tribunal also upheld the claimed short-term capital loss on sale of AIF units to a subsidiary, finding both acquisition and sale valuations followed the NAV method, the fall in value was explained by decline in underlying investments, and a related-party sale is not a colourable device without evidence of tax avoidance. Both revenue appeals were dismissed.
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