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...
Section 167B, which applies the maximum marginal rate where members' shares in an AOP or BOI are indeterminate or unknown, was held inapplicable to a society registered under the Karnataka Societies Registration Act, 1960 because the provision expressly excludes societies registered under the Societies Registration Act, 1860 or a corresponding law. The Tribunal therefore held that the apartment owners' welfare society was taxable at the normal applicable slab rates, not at the maximum marginal rate, with support from a coordinate bench decision and the Revenue's earlier acceptance of normal taxation.
Section 167B, which applies the maximum marginal rate where members' shares in an AOP or BOI are indeterminate or unknown, was held inapplicable to a society registered under the Karnataka Societies Registration Act, 1960 because the provision expressly excludes societies registered under the Societies Registration Act, 1860 or a corresponding law. The Tribunal therefore held that the apartment owners' welfare society was taxable at the normal applicable slab rates, not at the maximum marginal rate, with support from a coordinate bench decision and the Revenue's earlier acceptance of normal taxation.
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