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...
AO exceeded jurisdiction by disallowing claim of brought forward unabsorbed depreciation through rectification u/s 154, as CIT(A) did not direct such disallowance. CIT(A) order attained finality on this issue. Post CIT(A) order, AO cannot rectify u/s 154 in absence of mistake apparent from record. CIT(A) order upheld, Revenue's appeal dismissed.
AO exceeded jurisdiction by disallowing claim of brought forward unabsorbed depreciation through rectification u/s 154, as CIT(A) did not direct such disallowance. CIT(A) order attained finality on this issue. Post CIT(A) order, AO cannot rectify u/s 154 in absence of mistake apparent from record. CIT(A) order upheld, Revenue's appeal dismissed.
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