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...
Exemption u/s 11 - loss incurred out of corpus fund - What is taxable is the real income. If the AO’s view is to be accepted, it would lead to incongruous results. We say so because in the event, the assessee had earned profit in the instant transaction, the Revenue would have imposed tax on assessee. There cannot be different standards of examining facts when the assessee earns profit and when it suffers loss. - HC
Exemption u/s 11 - loss incurred out of corpus fund - What is taxable is the real income. If the AO’s view is to be accepted, it would lead to incongruous results. We say so because in the event, the assessee had earned profit in the instant transaction, the Revenue would have imposed tax on assessee. There cannot be different standards of examining facts when the assessee earns profit and when it suffers loss. - HC
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