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...
A securitisation trust constituted under the SARFAESI Act and governed by RBI guidelines was treated as a revocable trust, so its income was held taxable in the hands of the Security Receipt holders rather than in the hands of the trust. The trust was also held not assessable as an association of persons, and the rule relating to indeterminate shares was found inapplicable. In the absence of any distinguishing feature or contrary higher precedent, the appellate order was upheld and the Revenue's attempt to tax the trust was rejected.
A securitisation trust constituted under the SARFAESI Act and governed by RBI guidelines was treated as a revocable trust, so its income was held taxable in the hands of the Security Receipt holders rather than in the hands of the trust. The trust was also held not assessable as an association of persons, and the rule relating to indeterminate shares was found inapplicable. In the absence of any distinguishing feature or contrary higher precedent, the appellate order was upheld and the Revenue's attempt to tax the trust was rejected.
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