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...
Addition u/s 68 - unexplained credits - The provisions of Section 68 of the Act are attracted in case of unexplained credits during the relevant previous year. Since the outstanding loan/liability pertaining to BMPL and pertaining to SSL represent credits of earlier years, provisions of Section 68 would not be attracted in the facts and circumstances of the present case. - AT
Addition u/s 68 - unexplained credits - The provisions of Section 68 of the Act are attracted in case of unexplained credits during the relevant previous year. Since the outstanding loan/liability pertaining to BMPL and pertaining to SSL represent credits of earlier years, provisions of Section 68 would not be attracted in the facts and circumstances of the present case. - AT
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