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...
ITAT determined the tax treatment of a property sale, characterizing it as a short-term capital gain under section 50. The tribunal held that the property remained a business asset despite inconsistent depreciation claims, with its written down value as of 31.03.2003 (Rs. 33,02,106) to be reduced from the sale consideration (Rs. 1,45,00,000). Although classified as a short-term capital gain, the asset retains its long-term capital asset status, with tax rates applied under section 112. The tribunal allowed set-off of brought-forward long-term capital loss against the short-term capital gain, ultimately dismissing the assessee's primary contention.
ITAT determined the tax treatment of a property sale, characterizing it as a short-term capital gain under section 50. The tribunal held that the property remained a business asset despite inconsistent depreciation claims, with its written down value as of 31.03.2003 (Rs. 33,02,106) to be reduced from the sale consideration (Rs. 1,45,00,000). Although classified as a short-term capital gain, the asset retains its long-term capital asset status, with tax rates applied under section 112. The tribunal allowed set-off of brought-forward long-term capital loss against the short-term capital gain, ultimately dismissing the assessee's primary contention.
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