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 allowed the taxpayer's appeal, holding that payments of lease rentals made to the statutory development authority during the relevant fiscal year were not subject to deduction of tax at source under section 194-I prior to the date on which higher courts declared the provision to apply prospectively. The Tribunal found that the assessing authorities erred in treating the taxpayer as an "assessee in default" and in issuing orders under sections 201(1)/201(1A). Pursuant to the appellate and superior court pronouncements giving prospective effect to TDS applicability, the orders of the lower authorities and the CIT(A) were set aside and the taxpayer's appeal was allowed.
The ITAT allowed the taxpayer's appeal, holding that payments of lease rentals made to the statutory development authority during the relevant fiscal year were not subject to deduction of tax at source under section 194-I prior to the date on which higher courts declared the provision to apply prospectively. The Tribunal found that the assessing authorities erred in treating the taxpayer as an "assessee in default" and in issuing orders under sections 201(1)/201(1A). Pursuant to the appellate and superior court pronouncements giving prospective effect to TDS applicability, the orders of the lower authorities and the CIT(A) were set aside and the taxpayer's appeal was allowed.
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