Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Revision u/s 263 - Excessive payment to related party or not - Payments for job work not verified by AO at "fair market value" under section 40A(2)(b) - the onus is on the revenue to record reasons why payment by the assessee is excessive/unreasonable so as to invoke provisions of section 40A(2)(b) of the Act. For the foregoing reasons, in our view, PCIT has erred in facts and law in holding that the order is erroneous and prejudicial to the interests of the revenue - AT
Revision u/s 263 - Excessive payment to related party or not - Payments for job work not verified by AO at "fair market value" under section 40A(2)(b) - the onus is on the revenue to record reasons why payment by the assessee is excessive/unreasonable so as to invoke provisions of section 40A(2)(b) of the Act. For the foregoing reasons, in our view, PCIT has erred in facts and law in holding that the order is erroneous and prejudicial to the interests of the revenue - AT
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