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...
Land acquired in an individual's name for the appellant did not establish a real estate agent relationship, because the records showed the acquisition was on the appellant's behalf and no service was rendered to the housing society; the demand on that category was set aside. For works contract valuation, Rule 2A(ii) applies only when value cannot be determined under Rule 2A(i); the Revenue could not selectively accept some invoices and reject others without first determining the service portion, so the differential demand failed. The uncontested goods transport agency tax, already paid during audit, was confirmed.
Land acquired in an individual's name for the appellant did not establish a real estate agent relationship, because the records showed the acquisition was on the appellant's behalf and no service was rendered to the housing society; the demand on that category was set aside. For works contract valuation, Rule 2A(ii) applies only when value cannot be determined under Rule 2A(i); the Revenue could not selectively accept some invoices and reject others without first determining the service portion, so the differential demand failed. The uncontested goods transport agency tax, already paid during audit, was confirmed.
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