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 High Court considered the treatment of unsecured loans disallowed in tax assessment at 9% p.a. The ITAT, u/s CIT-Appeals, held that the Respondent explained the transactions satisfactorily. Referring to another ITAT decision, it found the addition to income was based on conjecture. The HC concluded that no substantial legal question was raised for appeal as the evidence supported the Respondent's position. This case did not involve accounting entries disguising transactions, and factual aspects were resolved in favor of the Respondent.
The High Court considered the treatment of unsecured loans disallowed in tax assessment at 9% p.a. The ITAT, u/s CIT-Appeals, held that the Respondent explained the transactions satisfactorily. Referring to another ITAT decision, it found the addition to income was based on conjecture. The HC concluded that no substantial legal question was raised for appeal as the evidence supported the Respondent's position. This case did not involve accounting entries disguising transactions, and factual aspects were resolved in favor of the Respondent.
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