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...
Cessation of liability u/s 41(1) - Notice issued u/s 133(6) could not be served upon the creditors - while the assessee has continued to declare the trading liability in its books of account, no benefit can be said to have been obtained in respect of such trading liability by way of remission or cessation thereof and thus the requirement of Section 41(1) are not satisfied - The additions made u/s 41(1) set aside and reversed. - AT
Cessation of liability u/s 41(1) - Notice issued u/s 133(6) could not be served upon the creditors - while the assessee has continued to declare the trading liability in its books of account, no benefit can be said to have been obtained in respect of such trading liability by way of remission or cessation thereof and thus the requirement of Section 41(1) are not satisfied - The additions made u/s 41(1) set aside and reversed. - AT
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