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...
Accumulated charitable income validly set aside under the pre-amendment section 11(2) regime remained available for application in the year immediately following the five-year accumulation period. The Finance Act 2022 omission of that additional utilisation year operated prospectively and did not curtail rights attached to accumulations made earlier. Accordingly, application in financial year 2022-23 of income accumulated in financial year 2016-17 was not deemed taxable income for assessment year 2023-24. Return-processing adjustments cannot disallow such a claim where eligibility depends on reconciling records and resolving debatable questions concerning statutory interpretation and the amendment's temporal operation.
Accumulated charitable income validly set aside under the pre-amendment section 11(2) regime remained available for application in the year immediately following the five-year accumulation period. The Finance Act 2022 omission of that additional utilisation year operated prospectively and did not curtail rights attached to accumulations made earlier. Accordingly, application in financial year 2022-23 of income accumulated in financial year 2016-17 was not deemed taxable income for assessment year 2023-24. Return-processing adjustments cannot disallow such a claim where eligibility depends on reconciling records and resolving debatable questions concerning statutory interpretation and the amendment's temporal operation.
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