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...
During a 2014 search operation, seized cash adjustment against advance tax liability was denied per Section 132B and Explanation 2. ITAT held that while self-assessment tax qualifies as 'existing liability', the assessee failed to include seized cash in total income computation. The matter of adjusting seized cash against self-assessment tax was remanded to AO for verification of circumstances similar to precedent case. Regarding interest u/s 220, ITAT ruled the assessee cannot be deemed in default as seized cash was already with Department within 30-day notice period. AO directed to adjust seized cash against tax liability if self-assessment tax adjustment relief is denied post verification.
During a 2014 search operation, seized cash adjustment against advance tax liability was denied per Section 132B and Explanation 2. ITAT held that while self-assessment tax qualifies as 'existing liability', the assessee failed to include seized cash in total income computation. The matter of adjusting seized cash against self-assessment tax was remanded to AO for verification of circumstances similar to precedent case. Regarding interest u/s 220, ITAT ruled the assessee cannot be deemed in default as seized cash was already with Department within 30-day notice period. AO directed to adjust seized cash against tax liability if self-assessment tax adjustment relief is denied post verification.
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