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...
The key points of the legal judgment by ITAT Delhi are as follows: The case involved the taxability of interest income on FDRs purchased by Uttarakhand Forest Corporation from UP Forest Corporation. The issue was whether the interest income accrued or was hypothetical. The tribunal held that since there was no certainty of realization of interest income due to unresolved negotiations between the state governments, taxing the unrealized interest income would be unjust. Citing precedents, the tribunal ruled that interest income should be taxed on receipt basis or when certainty is established, overturning the AO's additions.
The key points of the legal judgment by ITAT Delhi are as follows: The case involved the taxability of interest income on FDRs purchased by Uttarakhand Forest Corporation from UP Forest Corporation. The issue was whether the interest income accrued or was hypothetical. The tribunal held that since there was no certainty of realization of interest income due to unresolved negotiations between the state governments, taxing the unrealized interest income would be unjust. Citing precedents, the tribunal ruled that interest income should be taxed on receipt basis or when certainty is established, overturning the AO's additions.
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