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...
Warranty provision computed on a scientific basis was treated as deductible where it reflected a present obligation from past events, was likely to result in an outflow of resources, and could be reliably estimated; reopening on the same record was quashed because it ignored the governing principle on deductible warranty liability and material already disclosed. Reopening over forfeited security deposits linked to C-Forms was also invalid because the assessee had already disclosed the customer-wise details and the use of the amounts to meet sales tax liability, so the attempt amounted only to a change of opinion. On both grounds, reassessment was set aside.
Warranty provision computed on a scientific basis was treated as deductible where it reflected a present obligation from past events, was likely to result in an outflow of resources, and could be reliably estimated; reopening on the same record was quashed because it ignored the governing principle on deductible warranty liability and material already disclosed. Reopening over forfeited security deposits linked to C-Forms was also invalid because the assessee had already disclosed the customer-wise details and the use of the amounts to meet sales tax liability, so the attempt amounted only to a change of opinion. On both grounds, reassessment was set aside.
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