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...
Tribunal applied the commercial and accounting principle that sale of stock-in-trade is recognised when possession is handed over and consideration is received, and held that later formal registration does not create accrual of business income in a subsequent year. On the undisputed facts the assessee received consideration and delivered possession in the earlier year, VAT assessment corroborated that recognition, and the assessing officer failed to demonstrate any accrual in the impugned year. A provision akin to replacement-value assessment was inapplicable where no transfer occurred in the impugned year, and the same income cannot be taxed twice; revenue's appeal was dismissed.
Tribunal applied the commercial and accounting principle that sale of stock-in-trade is recognised when possession is handed over and consideration is received, and held that later formal registration does not create accrual of business income in a subsequent year. On the undisputed facts the assessee received consideration and delivered possession in the earlier year, VAT assessment corroborated that recognition, and the assessing officer failed to demonstrate any accrual in the impugned year. A provision akin to replacement-value assessment was inapplicable where no transfer occurred in the impugned year, and the same income cannot be taxed twice; revenue's appeal was dismissed.
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