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...
CIT u/s 263 has simply directed the AO, without satisfying himself, to verify whether the bifurcation made by assessee was with a view to reduce tax or not. No infirmity for offering the tax on sale of brands as LTCG. There is no merit in CIT’s observation for treating the same as business income. - AT
CIT u/s 263 has simply directed the AO, without satisfying himself, to verify whether the bifurcation made by assessee was with a view to reduce tax or not. No infirmity for offering the tax on sale of brands as LTCG. There is no merit in CIT’s observation for treating the same as business income. - AT
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