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...
Set off of brought forward business loss - mistakes in previous years for not claiming benefit of set-off - 8 years time limit provided in the statute - The ITAT found that the assessee had a legitimate assessed business loss from AY 2005-06, which was not set off against the business income in AY 2008-09 and 2009-10 due to an accountant's mistake. However, under Section 72 of the Act, such unadjusted business losses can be carried forward and set off against business income in up to 8 subsequent assessment years. The Tribunal concluded that the assessee was indeed eligible to set off the brought forward business loss against the business income of AY 2010-11, as it falls within the 8-year time limit.
Set off of brought forward business loss - mistakes in previous years for not claiming benefit of set-off - 8 years time limit provided in the statute - The ITAT found that the assessee had a legitimate assessed business loss from AY 2005-06, which was not set off against the business income in AY 2008-09 and 2009-10 due to an accountant's mistake. However, under Section 72 of the Act, such unadjusted business losses can be carried forward and set off against business income in up to 8 subsequent assessment years. The Tribunal concluded that the assessee was indeed eligible to set off the brought forward business loss against the business income of AY 2010-11, as it falls within the 8-year time limit.
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