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...
Rectification u/s 154 - under-assessment of income qua the foregoing depreciation/additional depreciation issue(s) - The Tribunal considered the Revenue’s contentions but found no merit in them. It was observed that the rectification proceedings under section 154 initiated by the Assessing Officer were not sustainable, as they involved a detailed re-computation of the assessee’s depreciation claims, which went beyond rectifying apparent mistakes on record. - In light of the decision of Supreme Court, the Tribunal dismissed the Revenue’s appeal, affirming the CIT(A)’s decision.
Rectification u/s 154 - under-assessment of income qua the foregoing depreciation/additional depreciation issue(s) - The Tribunal considered the Revenue’s contentions but found no merit in them. It was observed that the rectification proceedings under section 154 initiated by the Assessing Officer were not sustainable, as they involved a detailed re-computation of the assessee’s depreciation claims, which went beyond rectifying apparent mistakes on record. - In light of the decision of Supreme Court, the Tribunal dismissed the Revenue’s appeal, affirming the CIT(A)’s decision.
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