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...
Carry-forward of business losses requires the loss to be determined from a return filed under section 139(3) and quantified in assessment. Failure to file valid returns for intervening assessment years prevents determination and notification of the unabsorbed loss available for further carry-forward. Consequently, an earlier business loss cannot be set off in later years where intervening returns were not filed. The disallowance of the claimed set-off was upheld, and the appeals were dismissed because no substantial question of law arose.
Carry-forward of business losses requires the loss to be determined from a return filed under section 139(3) and quantified in assessment. Failure to file valid returns for intervening assessment years prevents determination and notification of the unabsorbed loss available for further carry-forward. Consequently, an earlier business loss cannot be set off in later years where intervening returns were not filed. The disallowance of the claimed set-off was upheld, and the appeals were dismissed because no substantial question of law arose.
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