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...
Inordinate delay of about 11 years was not condoned because a vague explanation based on ignorance of tax procedure, wrong advice and change of consultant did not show sufficient cause for the entire period; the appeal was therefore time-barred and not examined on merits. On the double taxation issue, the Tribunal accepted that the surrendered income in AY 2010-11 appeared to have been taxed again in reopened earlier years, applied the rule that the same income can be taxed only once, and directed deletion of the addition subject to verification that the amounts were identical.
Inordinate delay of about 11 years was not condoned because a vague explanation based on ignorance of tax procedure, wrong advice and change of consultant did not show sufficient cause for the entire period; the appeal was therefore time-barred and not examined on merits. On the double taxation issue, the Tribunal accepted that the surrendered income in AY 2010-11 appeared to have been taxed again in reopened earlier years, applied the rule that the same income can be taxed only once, and directed deletion of the addition subject to verification that the amounts were identical.
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