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...
Categorization of income - Undisclosed income surrendered during survey - Charging of tax rate u/s. 115BBE - CIT(A) granted relief to the assessee by charging income at normal rate of tax - We cannot subscribe to the view expressed by the CIT(A), since the AO has accepted the income offered by the assessee comes under the head ‘Income from Other Sources’ and offered higher rate of tax on the said income, therefore, there was no occasion for the AO to go into the integrities of the books of accounts to make them liable to be rejected. - AT
Categorization of income - Undisclosed income surrendered during survey - Charging of tax rate u/s. 115BBE - CIT(A) granted relief to the assessee by charging income at normal rate of tax - We cannot subscribe to the view expressed by the CIT(A), since the AO has accepted the income offered by the assessee comes under the head ‘Income from Other Sources’ and offered higher rate of tax on the said income, therefore, there was no occasion for the AO to go into the integrities of the books of accounts to make them liable to be rejected. - AT
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