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...
Rejection of books of account in derivative trading was unjustified where the books were audited and detailed trading statements were available; applying a fixed 12% of turnover as an arbitrary profit estimate lacked a reasonable basis. Because the assessing officer did not place material to support either the rejection of accounts or the turnover based estimation, the appellate deletion of the estimated business income was affirmed and the revenue's appeal was dismissed.
Rejection of books of account in derivative trading was unjustified where the books were audited and detailed trading statements were available; applying a fixed 12% of turnover as an arbitrary profit estimate lacked a reasonable basis. Because the assessing officer did not place material to support either the rejection of accounts or the turnover based estimation, the appellate deletion of the estimated business income was affirmed and the revenue's appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
