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...
Amounts characterized as death cum retirement gratuity and commuted pension were accepted as exempt under the relevant exemption provisions and must be excluded from salary for tax purposes; corresponding additions to salary were deleted. The reliance on a special tax on unexplained income for those salary additions was held inapplicable. A separate addition treating a time deposit as unexplained money was deleted because declared salary and exempt retirement receipts adequately accounted for the deposit and the addition rested on surmise without evidential foundation.
Amounts characterized as death cum retirement gratuity and commuted pension were accepted as exempt under the relevant exemption provisions and must be excluded from salary for tax purposes; corresponding additions to salary were deleted. The reliance on a special tax on unexplained income for those salary additions was held inapplicable. A separate addition treating a time deposit as unexplained money was deleted because declared salary and exempt retirement receipts adequately accounted for the deposit and the addition rested on surmise without evidential foundation.
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