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 Delhi High Court addressed the disallowance of provision for unsettled claims and Incurred But Not Reported (IBNR) Claims Reserve. The court held that the provision for outstanding claims can be allowed when materialized, not in the current year. The Tribunal's decision to delete the addition was justified as the provision was made based on claims lodged. The IBNR provisioning is regulated by the Insurance Regulatory and Development Authority of India Regulations, not considered a contingent liability. The court emphasized reasonable estimation and actuarial methods for liability quantification. The decision was against the revenue authority.
The Delhi High Court addressed the disallowance of provision for unsettled claims and Incurred But Not Reported (IBNR) Claims Reserve. The court held that the provision for outstanding claims can be allowed when materialized, not in the current year. The Tribunal's decision to delete the addition was justified as the provision was made based on claims lodged. The IBNR provisioning is regulated by the Insurance Regulatory and Development Authority of India Regulations, not considered a contingent liability. The court emphasized reasonable estimation and actuarial methods for liability quantification. The decision was against the revenue authority.
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