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 Coordinate Bench precedents to permit revised characterisation of investment sale proceeds as capital gains and to allow exemption for long term listed equity gains where the taxpayer chose that treatment; it allowed rent equalisation as a timing difference deduction and upheld allowability of insurance specific provisions including IBNR/IBNER and reinsurance premium deductions. The Tribunal set aside reversal of reserve for unexpired risks to the assessing officer for verification and compliance with Rule 6E conditions, and remitted recomputation and verification of interest to the assessing officer for recalculation in accordance with law.
Tribunal applied Coordinate Bench precedents to permit revised characterisation of investment sale proceeds as capital gains and to allow exemption for long term listed equity gains where the taxpayer chose that treatment; it allowed rent equalisation as a timing difference deduction and upheld allowability of insurance specific provisions including IBNR/IBNER and reinsurance premium deductions. The Tribunal set aside reversal of reserve for unexpired risks to the assessing officer for verification and compliance with Rule 6E conditions, and remitted recomputation and verification of interest to the assessing officer for recalculation in accordance with law.
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