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 of the assessee trust v/s AOP - The earlier returns filed relatable to the first PAN number issued was as a firm, and not as an AOP. Obviously, in the AY 2015-2016, the assessee filed a fresh application for registering the very same institution as a charitable institution under Section 12AA of the Act, without surrendering the earlier PAN issued in the very same name. This was to avail the benefit of Section 12AA. - the assessee from the above facts is guilty of misrepresentation and even fraud; prima facie, from the above disclosed facts - HC
Assessment of the assessee trust v/s AOP - The earlier returns filed relatable to the first PAN number issued was as a firm, and not as an AOP. Obviously, in the AY 2015-2016, the assessee filed a fresh application for registering the very same institution as a charitable institution under Section 12AA of the Act, without surrendering the earlier PAN issued in the very same name. This was to avail the benefit of Section 12AA. - the assessee from the above facts is guilty of misrepresentation and even fraud; prima facie, from the above disclosed facts - HC
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