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 ITAT upheld the AO's jurisdiction to conduct comprehensive scrutiny beyond the initial reasons for case selection, dismissing the assessee's objection. The Tribunal held that development charges received are revenue receipts, with no legal restriction on their utilization as prescribed by the government. Claims for TDS application of income and loan repayment as application of income were remanded for factual verification by the AO, directing allowance if conditions are met. The Tribunal ruled that the restriction on setting off brought forward deficits under Explanation 5 to section 11(1) is prospective, permitting set off for the relevant year subject to verification. The issue of GST/ST deduction was remanded for AO's verification to determine its applicability as application of income.
The ITAT upheld the AO's jurisdiction to conduct comprehensive scrutiny beyond the initial reasons for case selection, dismissing the assessee's objection. The Tribunal held that development charges received are revenue receipts, with no legal restriction on their utilization as prescribed by the government. Claims for TDS application of income and loan repayment as application of income were remanded for factual verification by the AO, directing allowance if conditions are met. The Tribunal ruled that the restriction on setting off brought forward deficits under Explanation 5 to section 11(1) is prospective, permitting set off for the relevant year subject to verification. The issue of GST/ST deduction was remanded for AO's verification to determine its applicability as application of income.
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