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 issue is whether the assessee was an agent of an NRI partner such that income received by a partnership would be attributable to the assessee; the tribunal found the development agreement was with the partnership firm (five partners) not the individual NRI, there was no direct or indirect contractual or business connection between the assessee and the NRI partner, and income flowed to partners from the firm; therefore the tax authority failed to establish agency and the addition made invoking agent-attribution provisions was deleted in favour of the assessee.
The issue is whether the assessee was an agent of an NRI partner such that income received by a partnership would be attributable to the assessee; the tribunal found the development agreement was with the partnership firm (five partners) not the individual NRI, there was no direct or indirect contractual or business connection between the assessee and the NRI partner, and income flowed to partners from the firm; therefore the tax authority failed to establish agency and the addition made invoking agent-attribution provisions was deleted in favour of the assessee.
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