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...
Additions - under pricing to sister concern - This action of the A.O. is unjustified. Hence, the addition on account of underpricing was not warranted. The assessing officer missed the vital point that income was below taxable limit after b/f losses were set off during the current year. Moreover, there was no finding by the lower authorities that sister concerns benefited in any manner.
Additions - under pricing to sister concern - This action of the A.O. is unjustified. Hence, the addition on account of underpricing was not warranted. The assessing officer missed the vital point that income was below taxable limit after b/f losses were set off during the current year. Moreover, there was no finding by the lower authorities that sister concerns benefited in any manner.
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