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...
Concessional tax rate under section 115BAA is available where the taxpayer clearly exercised the option in the return and satisfied statutory conditions; delayed filing of prescribed Form 10 IC was treated as a procedural lapse eligible for condonation and the Tribunal directed acceptance of the concessional rate. The Tribunal applied the principle that procedure should not defeat substantive rights absent prejudice to revenue, relying on an administrative clarification by CBDT to permit extended filing. The Tribunal also held that it retained appellate jurisdiction to re determine the correct tax computation in the assessment despite parallel proceedings on the intimation.
Concessional tax rate under section 115BAA is available where the taxpayer clearly exercised the option in the return and satisfied statutory conditions; delayed filing of prescribed Form 10 IC was treated as a procedural lapse eligible for condonation and the Tribunal directed acceptance of the concessional rate. The Tribunal applied the principle that procedure should not defeat substantive rights absent prejudice to revenue, relying on an administrative clarification by CBDT to permit extended filing. The Tribunal also held that it retained appellate jurisdiction to re determine the correct tax computation in the assessment despite parallel proceedings on the intimation.
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