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...
Leased premises used as a hotel, though containing a restaurant, banquet and conference halls, bar and health club, qualify as a building used for accommodation and thus fall within the renting of immovable property exclusion; the Tribunal found those facilities to be integral or incidental to hotel activity rather than separate commercial deployments and held that Explanation 2 deeming partial business use is not attracted. Applying the plain-text exclusion and following prior coordinate-bench reasoning affirmed by higher authority, the impugned demand and orders were set aside with consequential relief.
Leased premises used as a hotel, though containing a restaurant, banquet and conference halls, bar and health club, qualify as a building used for accommodation and thus fall within the renting of immovable property exclusion; the Tribunal found those facilities to be integral or incidental to hotel activity rather than separate commercial deployments and held that Explanation 2 deeming partial business use is not attracted. Applying the plain-text exclusion and following prior coordinate-bench reasoning affirmed by higher authority, the impugned demand and orders were set aside with consequential relief.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
