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...
Assessee arrived at business income after setting off losses. Assessee's entitlement to carry forward losses was revised due to application of Section 79. Case was reopened u/s 147 after obtaining approval u/s 148, citing revision of assessee's entitlement to carry forward losses due to Section 79 application. Claims were examined during original assessment proceedings, and no error prejudicial to Revenue's interests was found. Inadequate inquiry by Assessing Officer regarding certain claims does not warrant invoking Section 263 powers. Revenue failed to establish that Commissioner exercised power in accordance with law. Facts do not fulfill twin conditions of Section 263. Decided in favor of assessee.
Assessee arrived at business income after setting off losses. Assessee's entitlement to carry forward losses was revised due to application of Section 79. Case was reopened u/s 147 after obtaining approval u/s 148, citing revision of assessee's entitlement to carry forward losses due to Section 79 application. Claims were examined during original assessment proceedings, and no error prejudicial to Revenue's interests was found. Inadequate inquiry by Assessing Officer regarding certain claims does not warrant invoking Section 263 powers. Revenue failed to establish that Commissioner exercised power in accordance with law. Facts do not fulfill twin conditions of Section 263. Decided in favor of assessee.
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