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 High Court remanded the proceedings to the Assessing Officer to consider the assessee's alternate claim for loss arising out of Held till Maturity securities under the head 'income from business and profession'. The Income Tax Appellate Tribunal's finding that no material was supplied by the assessee to substantiate the claim was held unsustainable. The assessee accepted the Income Tax Appellate Tribunal's decision treating profits from the sale of Held till Maturity securities as capital gains.
The High Court remanded the proceedings to the Assessing Officer to consider the assessee's alternate claim for loss arising out of Held till Maturity securities under the head 'income from business and profession'. The Income Tax Appellate Tribunal's finding that no material was supplied by the assessee to substantiate the claim was held unsustainable. The assessee accepted the Income Tax Appellate Tribunal's decision treating profits from the sale of Held till Maturity securities as capital gains.
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