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...
Depreciation on non-compete fee was treated as a consequential effect of an earlier appellate order, and the Revenue's objection was rejected because the Commissioner (Appeals) only directed implementation of that prior decision. Cost of production of TV serials and programmes was allowed as revenue expenditure on the basis of consistency, as the issue had already been decided in the assessee's favour for an earlier year and no contrary higher-court order was shown. Subscription revenue recognition was remanded because the dispute turned on verification of actual and real income, not merely the choice between mercantile and cash accounting; the Assessing Officer must examine the factual correctness of the estimated and actual figures.
Depreciation on non-compete fee was treated as a consequential effect of an earlier appellate order, and the Revenue's objection was rejected because the Commissioner (Appeals) only directed implementation of that prior decision. Cost of production of TV serials and programmes was allowed as revenue expenditure on the basis of consistency, as the issue had already been decided in the assessee's favour for an earlier year and no contrary higher-court order was shown. Subscription revenue recognition was remanded because the dispute turned on verification of actual and real income, not merely the choice between mercantile and cash accounting; the Assessing Officer must examine the factual correctness of the estimated and actual figures.
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