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...
Assessment framed u/s.153A - computation of period of 6 years / 10 years in search cases - amendment of provisions of section 1153A(1)(b) - while computing ten assessment years, the starting point has to be the end of the search assessment year - CIT(A) rightly held that the 10th assessment year counted from this AY 2018-19 is AY 2009-10 and he held that notice issued u/s. 153A of the Act for AY 2008-09 could not have been issued. - AT
Assessment framed u/s.153A - computation of period of 6 years / 10 years in search cases - amendment of provisions of section 1153A(1)(b) - while computing ten assessment years, the starting point has to be the end of the search assessment year - CIT(A) rightly held that the 10th assessment year counted from this AY 2018-19 is AY 2009-10 and he held that notice issued u/s. 153A of the Act for AY 2008-09 could not have been issued. - AT
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