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...
Revision u/s 263 - Gain on cancellation of forwarding contract - characterization of income - Revenue may be correct in contending that, the Assessing Officer had not carried out detailed enquiries that by itself would not be sufficient to enable the Commissioner to exercise revisional power if based on materials already on record come to the same conclusion that amount is capital nature and not taxable.
Revision u/s 263 - Gain on cancellation of forwarding contract - characterization of income - Revenue may be correct in contending that, the Assessing Officer had not carried out detailed enquiries that by itself would not be sufficient to enable the Commissioner to exercise revisional power if based on materials already on record come to the same conclusion that amount is capital nature and not taxable.
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