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 10(26) exemption for a Scheduled Tribe assessee is not automatic; it applies only when the statutory conditions coexist, including that the salary income accrues or arises from a source situated in the notified area. Salary generally accrues where the services are performed, so the employer's office location is not decisive. On the record produced, the employer's certificate only showed current work-from-home status and did not establish that the assessee worked from Meghalaya for the full relevant year, while the employment terms were not produced. The Tribunal therefore remanded the exemption claim to the Assessing Officer for fresh consideration.
Section 10(26) exemption for a Scheduled Tribe assessee is not automatic; it applies only when the statutory conditions coexist, including that the salary income accrues or arises from a source situated in the notified area. Salary generally accrues where the services are performed, so the employer's office location is not decisive. On the record produced, the employer's certificate only showed current work-from-home status and did not establish that the assessee worked from Meghalaya for the full relevant year, while the employment terms were not produced. The Tribunal therefore remanded the exemption claim to the Assessing Officer for fresh consideration.
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