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...
Income estimation based on percentage of gross receipts - CIT(A) applied 12.5% net profit on gross receipts, assessee claimed thin margins in advertisement business. ITAT held some guesswork inevitable without financial data. CIT(A) lacked material for 12.5%, assessee failed to substantiate lower 1.5-2% claim. Section 44AD deems 8% of turnover as business income for eligible assessees based on empirical data. Guided by equity, ITAT considered 8% of gross receipts fair estimation, modifying CIT(A)'s 12.5% to 8%. Assessee's appeal partly allowed.
Income estimation based on percentage of gross receipts - CIT(A) applied 12.5% net profit on gross receipts, assessee claimed thin margins in advertisement business. ITAT held some guesswork inevitable without financial data. CIT(A) lacked material for 12.5%, assessee failed to substantiate lower 1.5-2% claim. Section 44AD deems 8% of turnover as business income for eligible assessees based on empirical data. Guided by equity, ITAT considered 8% of gross receipts fair estimation, modifying CIT(A)'s 12.5% to 8%. Assessee's appeal partly allowed.
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