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 - Disallowance u/s 40(a)(ia) on non deduction of TDS - The Tribunal found that the Principal Commissioner had incorrectly invoked section 263 as the payments and Tax Deducted at Source (TDS) were related to the subsequent financial year and there was no revenue implication or prejudice to the Revenue.
Revision u/s 263 - Disallowance u/s 40(a)(ia) on non deduction of TDS - The Tribunal found that the Principal Commissioner had incorrectly invoked section 263 as the payments and Tax Deducted at Source (TDS) were related to the subsequent financial year and there was no revenue implication or prejudice to the Revenue.
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