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...
Reward under the informant guidelines was treated as ex gratia and subject to the competent authority's discretion, with relaxation beyond the prescribed ceiling resting with the Full Board. The informant had accepted that the payment was non-contractual and would not be challenged in court. After re-examining the tax recovery, supplied information and weightage methodology, the Board recalculated the reward and found the earlier recommendation incorrect. The Court declined to substitute its own assessment, holding that writ interference was unavailable absent manifest illegality or patent arbitrariness. The enhanced claim was rejected and the writ petition dismissed.
Reward under the informant guidelines was treated as ex gratia and subject to the competent authority's discretion, with relaxation beyond the prescribed ceiling resting with the Full Board. The informant had accepted that the payment was non-contractual and would not be challenged in court. After re-examining the tax recovery, supplied information and weightage methodology, the Board recalculated the reward and found the earlier recommendation incorrect. The Court declined to substitute its own assessment, holding that writ interference was unavailable absent manifest illegality or patent arbitrariness. The enhanced claim was rejected and the writ petition dismissed.
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