Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Amounts received by the appellant company from Offshore Supply Contracts were held not liable to tax in India u/s 44BBB. The Coordinate Bench consistently held that receipts towards offshore supply contracts cannot form part of business income chargeable u/s 44BBB, even if certain functions were required to be performed after equipment sale. The Income Tax Appellate Tribunal (ITAT) upheld this position, disallowing the departmental representative's contention as an attempt to improve the assessing officer's case. The assessee's appeal was allowed.
Amounts received by the appellant company from Offshore Supply Contracts were held not liable to tax in India u/s 44BBB. The Coordinate Bench consistently held that receipts towards offshore supply contracts cannot form part of business income chargeable u/s 44BBB, even if certain functions were required to be performed after equipment sale. The Income Tax Appellate Tribunal (ITAT) upheld this position, disallowing the departmental representative's contention as an attempt to improve the assessing officer's case. The assessee's appeal was allowed.
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