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...
Valuation of unquoted shares under the prescribed framework allows the assessee to choose either the Discounted Cash Flow (DCF) or Net Asset Value (NAV) method. Where DCF is selected, the Assessing Officer may examine the underlying data and projections and obtain or determine a fresh valuation if they are unreliable or unrealistic, but must continue under the DCF method. The notes state that substituting NAV for the assessee's chosen DCF method exceeds the Assessing Officer's jurisdiction; accordingly, the NAV-based addition discussed was deleted.
Valuation of unquoted shares under the prescribed framework allows the assessee to choose either the Discounted Cash Flow (DCF) or Net Asset Value (NAV) method. Where DCF is selected, the Assessing Officer may examine the underlying data and projections and obtain or determine a fresh valuation if they are unreliable or unrealistic, but must continue under the DCF method. The notes state that substituting NAV for the assessee's chosen DCF method exceeds the Assessing Officer's jurisdiction; accordingly, the NAV-based addition discussed was deleted.
Note: It is a system-generated summary and is for quick reference only.
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