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...
Unsupported estimation of indexed acquisition and construction or improvement costs cannot sustain capital-gains additions where neither the taxpayers' claims nor the Assessing Officer's adopted land and construction rates are supported by evidence. The reported tribunal decision deleted the resulting cost adjustments in all appeals. For section 54F, acquisition of a new residential property within the statutory period preserves the exemption despite non-deposit of interim unutilised gains in the Capital Gains Account Scheme, treating that omission as procedural. Exemption was allowed for investments made within time, but remained unavailable where the residential-property investment itself occurred beyond the prescribed period.
Unsupported estimation of indexed acquisition and construction or improvement costs cannot sustain capital-gains additions where neither the taxpayers' claims nor the Assessing Officer's adopted land and construction rates are supported by evidence. The reported tribunal decision deleted the resulting cost adjustments in all appeals. For section 54F, acquisition of a new residential property within the statutory period preserves the exemption despite non-deposit of interim unutilised gains in the Capital Gains Account Scheme, treating that omission as procedural. Exemption was allowed for investments made within time, but remained unavailable where the residential-property investment itself occurred beyond the prescribed period.
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