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...
Power of CIT(A) enhancing the income of the assessee u/s. 251(1)(a) r.w.s. 251(2) - The Ld. CIT(A) is not empowered to enhance the assessment by computing book profits U/s. 115JB of the Act, as it is a separate code. - This issue whether book profits can be computed U/s. 115JB of the Act, when the GTI and TI of the assessee are Nil and no taxes payable, is adjudicated in favour of the assessee - AT
Power of CIT(A) enhancing the income of the assessee u/s. 251(1)(a) r.w.s. 251(2) - The Ld. CIT(A) is not empowered to enhance the assessment by computing book profits U/s. 115JB of the Act, as it is a separate code. - This issue whether book profits can be computed U/s. 115JB of the Act, when the GTI and TI of the assessee are Nil and no taxes payable, is adjudicated in favour of the assessee - AT
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