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 offered translation gain from revenue transactions for taxation. CIT(A) deleted disallowance of translation gain from merger of branch balance sheet, holding it non-taxable based on ICAI accounting standards and consistency principle. CBDT circular clarified such translation gains/losses are not real income, upheld by Delhi High Court. Excise duty refunds received by assessee were treated as capital receipts by CIT(A), not taxable revenue receipts, based on Gujarat High Court ruling that refunds aimed to promote industries satisfy 'purpose test' for capital nature. ITAT upheld CIT(A)'s decisions on both issues in favor of assessee.
Assessee offered translation gain from revenue transactions for taxation. CIT(A) deleted disallowance of translation gain from merger of branch balance sheet, holding it non-taxable based on ICAI accounting standards and consistency principle. CBDT circular clarified such translation gains/losses are not real income, upheld by Delhi High Court. Excise duty refunds received by assessee were treated as capital receipts by CIT(A), not taxable revenue receipts, based on Gujarat High Court ruling that refunds aimed to promote industries satisfy 'purpose test' for capital nature. ITAT upheld CIT(A)'s decisions on both issues in favor of assessee.
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