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...
Where an assessee disputes stamp-duty valuation under section 56(2)(x), distinguishes the valuation of different portions of the property, and requests a reference to the Departmental Valuation Officer, the Assessing Officer must make that reference before adopting the stamp-duty value. The basement and ground floor could not be valued on the same basis without addressing the assessee's objections through a reasoned finding. Adoption of the stamp-duty valuation without a valuation reference was therefore unjustified, and the addition for the difference between declared purchase consideration and stamp-duty value was deleted to the assessee's share.
Where an assessee disputes stamp-duty valuation under section 56(2)(x), distinguishes the valuation of different portions of the property, and requests a reference to the Departmental Valuation Officer, the Assessing Officer must make that reference before adopting the stamp-duty value. The basement and ground floor could not be valued on the same basis without addressing the assessee's objections through a reasoned finding. Adoption of the stamp-duty valuation without a valuation reference was therefore unjustified, and the addition for the difference between declared purchase consideration and stamp-duty value was deleted to the assessee's share.
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