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 - Characterization of receipts - Exemption of interest on enhanced compensation from tax denied u/s. 10(37) - However, the Appellate Tribunal dismissed the appeal, affirming the Assessing Officer's decision to tax 50% of the interest. The Tribunal held that the interest did not fall under section 28 of the LAA and was taxable as income. The plea for rectification under section 154 was rejected as there was no mistake in the assessment order.
Rectification u/s 154 - Characterization of receipts - Exemption of interest on enhanced compensation from tax denied u/s. 10(37) - However, the Appellate Tribunal dismissed the appeal, affirming the Assessing Officer's decision to tax 50% of the interest. The Tribunal held that the interest did not fall under section 28 of the LAA and was taxable as income. The plea for rectification under section 154 was rejected as there was no mistake in the assessment order.
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