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...
Selective revaluation noted by the auditor did not by itself disqualify certified accounts for MAT purposes or justify excluding depreciation on the revaluation component from book profit. The High Court held that once the accounts complied with the Companies Act and were certified under the statutory audit framework, the Assessing Officer could not go behind the book profit except to the limited extent permitted under the MAT provisions. The Tribunal erred in treating the auditor's qualification note as undermining the true and fair view of the accounts; the assessee succeeded and the CIT(A)'s order was restored.
Selective revaluation noted by the auditor did not by itself disqualify certified accounts for MAT purposes or justify excluding depreciation on the revaluation component from book profit. The High Court held that once the accounts complied with the Companies Act and were certified under the statutory audit framework, the Assessing Officer could not go behind the book profit except to the limited extent permitted under the MAT provisions. The Tribunal erred in treating the auditor's qualification note as undermining the true and fair view of the accounts; the assessee succeeded and the CIT(A)'s order was restored.
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