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 a registered sale deed was subsequently cancelled by a registered cancellation deed and the purchaser's share of the sale consideration was repaid as recorded in the cancellation deed, there was no subsisting transfer or benefit taxable as imputed income under the gifts/imputed-income provision; the cancellation with repayment removed the legal basis for treating the difference between stamp valuation and declared consideration as income, and the addition made on that ground was deleted with the appeal allowed.
Where a registered sale deed was subsequently cancelled by a registered cancellation deed and the purchaser's share of the sale consideration was repaid as recorded in the cancellation deed, there was no subsisting transfer or benefit taxable as imputed income under the gifts/imputed-income provision; the cancellation with repayment removed the legal basis for treating the difference between stamp valuation and declared consideration as income, and the addition made on that ground was deleted with the appeal allowed.
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