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 - Capital gain on property of the respective HUFs or respective individual assessee's - Merely because land is divided, with a view to avoid family dispute, by the father between himself and his two sons, would not by itself make it a family property. No case, either on facts or in law is made out. To us, it is no more than a father dividing his property, self-acquired as well as that bequeathed to him by his father, between his two sons, also retaining a part for himself (5.45 acres). In short, the claim is without basis and wholly unproved; in fact, fatuous. - AT
Revision u/s 263 - Capital gain on property of the respective HUFs or respective individual assessee's - Merely because land is divided, with a view to avoid family dispute, by the father between himself and his two sons, would not by itself make it a family property. No case, either on facts or in law is made out. To us, it is no more than a father dividing his property, self-acquired as well as that bequeathed to him by his father, between his two sons, also retaining a part for himself (5.45 acres). In short, the claim is without basis and wholly unproved; in fact, fatuous. - AT
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