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 assessing officer made protective additions u/ss 69, 69C, and 68 for amounts already considered by the firm where the assessee was a partner. However, the settlement commission's order dated 03.12.2020, containing entries from serial numbers 1 to 2402 for which additions were made by the assessing officer on a protective basis, was not disputed by the revenue. Since the additions accepted by the firm were not contested by the revenue, they cannot be sustained in the assessee's hands on a protective basis. Consequently, the ground raised by the assessee stands allowed by the Income Tax Appellate Tribunal.
The assessing officer made protective additions u/ss 69, 69C, and 68 for amounts already considered by the firm where the assessee was a partner. However, the settlement commission's order dated 03.12.2020, containing entries from serial numbers 1 to 2402 for which additions were made by the assessing officer on a protective basis, was not disputed by the revenue. Since the additions accepted by the firm were not contested by the revenue, they cannot be sustained in the assessee's hands on a protective basis. Consequently, the ground raised by the assessee stands allowed by the Income Tax Appellate Tribunal.
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