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...
Reassessment proceedings under section 147 are confined to bringing escaped or under-assessed income to tax and cannot be used by an assessee to reopen a concluded matter or withdraw income voluntarily offered in the original return. Where the income had been disclosed under section 139(1), a return filed in response to section 148 could not be used to reduce assessed house property income or obtain review of the original position. The addition was sustained, the merits of the ownership-based explanation were left open as academic, and the appellate order was upheld.
Reassessment proceedings under section 147 are confined to bringing escaped or under-assessed income to tax and cannot be used by an assessee to reopen a concluded matter or withdraw income voluntarily offered in the original return. Where the income had been disclosed under section 139(1), a return filed in response to section 148 could not be used to reduce assessed house property income or obtain review of the original position. The addition was sustained, the merits of the ownership-based explanation were left open as academic, and the appellate order was upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
