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 allowed the appeal and remanded the case for reassessment. The Tribunal found procedural irregularities in the assessment order, specifically noting that the Assessing Officer (AO) did not provide the assessee an opportunity to submit a Valuation Report from a Merchant Banker using Discounted Cash Flow (DCF) method. The Tribunal directed the assessee to procure a fresh Valuation Report compliant with Rule 11UA of Income Tax Rules, 1962, and instructed the CIT(A) to review the report, obtain a remand report from AO, and provide reasonable hearing opportunity to the assessee before making a final determination on the share premium addition under Section 56(2)(viib).
ITAT allowed the appeal and remanded the case for reassessment. The Tribunal found procedural irregularities in the assessment order, specifically noting that the Assessing Officer (AO) did not provide the assessee an opportunity to submit a Valuation Report from a Merchant Banker using Discounted Cash Flow (DCF) method. The Tribunal directed the assessee to procure a fresh Valuation Report compliant with Rule 11UA of Income Tax Rules, 1962, and instructed the CIT(A) to review the report, obtain a remand report from AO, and provide reasonable hearing opportunity to the assessee before making a final determination on the share premium addition under Section 56(2)(viib).
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