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 - As per CIT AO has not called for any details to ascertain the amount and nature of total remittances received by the assessee during the year - various inconsistencies in the approach of learned CIT gives an impression that he himself was not sure about the nature and character of shipping income earned by the assessee. - CIT was not justified in assuming jurisdiction u/s 263 - AT
Revision u/s 263 - As per CIT AO has not called for any details to ascertain the amount and nature of total remittances received by the assessee during the year - various inconsistencies in the approach of learned CIT gives an impression that he himself was not sure about the nature and character of shipping income earned by the assessee. - CIT was not justified in assuming jurisdiction u/s 263 - AT
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