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...
Determination of acquisition year for Long-Term Capital Gains hinges on transfer effected by handing over possession in part performance; registration date does not shift the year of acquisition once possession and consideration were transferred, so the FY 1996-97 Cost Inflation Index applies. The tribunal rejects need for independent third party corroboration where no adverse material exists and accords evidentiary weight to the registered document. On deduction of construction cost, the tribunal applied the principle of consistency and parity among similarly placed co owners, directing that construction and improvement costs accepted in co owners' cases be allowed mutatis mutandis to the assessee.
Determination of acquisition year for Long-Term Capital Gains hinges on transfer effected by handing over possession in part performance; registration date does not shift the year of acquisition once possession and consideration were transferred, so the FY 1996-97 Cost Inflation Index applies. The tribunal rejects need for independent third party corroboration where no adverse material exists and accords evidentiary weight to the registered document. On deduction of construction cost, the tribunal applied the principle of consistency and parity among similarly placed co owners, directing that construction and improvement costs accepted in co owners' cases be allowed mutatis mutandis to the assessee.
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