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...
Revised post-survey construction cost estimates, TDR and development rights allocation, and GST impact on project cost under the Percentage of Completion Method depended on detailed factual verification. The text notes that the revised projections were linked to changes in floor plans, phase-wise utilisation of development rights, denial of input tax credit under the revised GST scheme, and consistency of revenue recognition with registered agreements. It records that broad explanations and estimated workings were insufficient, so the revised computation could not be finally accepted without examining the factual foundation. The disputed additions were therefore set aside and the matter was remanded for de novo verification and fresh decision for both assessment years.
Revised post-survey construction cost estimates, TDR and development rights allocation, and GST impact on project cost under the Percentage of Completion Method depended on detailed factual verification. The text notes that the revised projections were linked to changes in floor plans, phase-wise utilisation of development rights, denial of input tax credit under the revised GST scheme, and consistency of revenue recognition with registered agreements. It records that broad explanations and estimated workings were insufficient, so the revised computation could not be finally accepted without examining the factual foundation. The disputed additions were therefore set aside and the matter was remanded for de novo verification and fresh decision for both assessment years.
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