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...
Section 143(1) processing may continue after issuance of a scrutiny notice under section 143(2) for returns from assessment years commencing on or after 1 April 2017. The note explains that merger is issue-specific: only matters actually examined and decided in subsequent scrutiny merge, so unexamined processing adjustments remain separate matters arising from the intimation. It also states that an Assessing Officer need not revisit CPC adjustments merely because scrutiny follows. Cross-charged ESOP costs reimbursed by an Indian subsidiary to its foreign parent are described as employee compensation incurred wholly and exclusively for business, rather than capital expenditure, where the subsidiary neither issues shares nor acquires a capital asset.
Section 143(1) processing may continue after issuance of a scrutiny notice under section 143(2) for returns from assessment years commencing on or after 1 April 2017. The note explains that merger is issue-specific: only matters actually examined and decided in subsequent scrutiny merge, so unexamined processing adjustments remain separate matters arising from the intimation. It also states that an Assessing Officer need not revisit CPC adjustments merely because scrutiny follows. Cross-charged ESOP costs reimbursed by an Indian subsidiary to its foreign parent are described as employee compensation incurred wholly and exclusively for business, rather than capital expenditure, where the subsidiary neither issues shares nor acquires a capital asset.
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