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...
Admissibility of additional evidence submitted during remand reconciled GSTR 1 entries with profit and loss turnover, leading to deletion of a turnover discrepancy addition because the Assessing Officer's remand report attributed the variance to earlier years. Recognition of interest on service concession receivable and deferred retention liability in the profit and loss account was treated as notional income recorded to comply with accounting standards (IND AS) and not taxable as actual income in the relevant year; the Tribunal sustained deletion of the section 56 addition, noting subsequent assessments accepted actual annuity interest treatment. Revenue appeal dismissed on both points.
Admissibility of additional evidence submitted during remand reconciled GSTR 1 entries with profit and loss turnover, leading to deletion of a turnover discrepancy addition because the Assessing Officer's remand report attributed the variance to earlier years. Recognition of interest on service concession receivable and deferred retention liability in the profit and loss account was treated as notional income recorded to comply with accounting standards (IND AS) and not taxable as actual income in the relevant year; the Tribunal sustained deletion of the section 56 addition, noting subsequent assessments accepted actual annuity interest treatment. Revenue appeal dismissed on both points.
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