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...
Surrendered income arising from business activity was not assessable as unexplained income under the deeming provisions where the record showed only regular business income and no separate unexplained source. The Tribunal applied the principle that, unless the Revenue establishes an independent source outside the business, an amount surrendered in the course of business is treated as normal business income. On that basis, the sustained addition was directed to be assessed as business income and not under the unexplained-income regime, and the appeal was partly allowed.
Surrendered income arising from business activity was not assessable as unexplained income under the deeming provisions where the record showed only regular business income and no separate unexplained source. The Tribunal applied the principle that, unless the Revenue establishes an independent source outside the business, an amount surrendered in the course of business is treated as normal business income. On that basis, the sustained addition was directed to be assessed as business income and not under the unexplained-income regime, and the appeal was partly allowed.
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