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...
Where the Assessing Officer recorded inconsistencies between the return, balance sheet and construction agreement and expressly considered then rejected the assessee's books of account, referral to the District Valuation Officer for valuation was held permissible; the court applied the principle that a DVO report may be relied on only after rejection of books and found that factual record satisfied that rule. The HC endorsed the Tribunal and CIT(A) directions, approved adoption of State PWD rates for valuation, treated the omitted investment as escaped income and dismissed the tax appeal.
Where the Assessing Officer recorded inconsistencies between the return, balance sheet and construction agreement and expressly considered then rejected the assessee's books of account, referral to the District Valuation Officer for valuation was held permissible; the court applied the principle that a DVO report may be relied on only after rejection of books and found that factual record satisfied that rule. The HC endorsed the Tribunal and CIT(A) directions, approved adoption of State PWD rates for valuation, treated the omitted investment as escaped income and dismissed the tax appeal.
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