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 HC upheld the Tribunal's remand to the AO for fresh adjudication on the assessee's entitlement to deductions under s.80JJA for AYs 2007-08 and 2008-09, finding no infirmity warranting rectification of the Tribunal's order and affirming the Tribunal's power under s.254 to remit for reconsideration; the Court noted that the claim under s.80JJA could not be arbitrarily disallowed where it had been allowed in earlier years on identical facts. Separately, the HC found the addition u/s 68 unsustainable on the record, observed that bank payments and confirmations substantiated the sundry creditors, and remitted the matter to the AO for de novo assessment.
The HC upheld the Tribunal's remand to the AO for fresh adjudication on the assessee's entitlement to deductions under s.80JJA for AYs 2007-08 and 2008-09, finding no infirmity warranting rectification of the Tribunal's order and affirming the Tribunal's power under s.254 to remit for reconsideration; the Court noted that the claim under s.80JJA could not be arbitrarily disallowed where it had been allowed in earlier years on identical facts. Separately, the HC found the addition u/s 68 unsustainable on the record, observed that bank payments and confirmations substantiated the sundry creditors, and remitted the matter to the AO for de novo assessment.
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