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...
Income recognised on completion of consultancy services and invoicing should not be taxed again merely because the related tax credit appears in Form 26AS in a later year; the reported addition was deleted after reconciliation of the invoices. Property-transfer charges and commission, although not deductible as business expenditure, were to be considered in computing capital gains because they related to the sale. Professional fees claimed for arranging working-capital funding required proof of their business utility; in the absence of adequate substantiation, only part of the claim was allowed and half was disallowed. The appeal was partly allowed.
Income recognised on completion of consultancy services and invoicing should not be taxed again merely because the related tax credit appears in Form 26AS in a later year; the reported addition was deleted after reconciliation of the invoices. Property-transfer charges and commission, although not deductible as business expenditure, were to be considered in computing capital gains because they related to the sale. Professional fees claimed for arranging working-capital funding required proof of their business utility; in the absence of adequate substantiation, only part of the claim was allowed and half was disallowed. The appeal was partly allowed.
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