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...
The note addresses tax consequences of undisputed TDS non-deduction and unexplained loan credits: the applicable disallowance for failure to deduct tax at source is confined to thirty percent of the admitted shortfall, limiting the assessor's large-scale disallowance to that proportion; and an addition treated as unexplained cash credit based on increased unsecured loans was deleted where the assessee furnished primary documents (confirmations, ITRs, bank statements), shifting the onus to the revenue to rebut those records and no adverse material was produced.
The note addresses tax consequences of undisputed TDS non-deduction and unexplained loan credits: the applicable disallowance for failure to deduct tax at source is confined to thirty percent of the admitted shortfall, limiting the assessor's large-scale disallowance to that proportion; and an addition treated as unexplained cash credit based on increased unsecured loans was deleted where the assessee furnished primary documents (confirmations, ITRs, bank statements), shifting the onus to the revenue to rebut those records and no adverse material was produced.
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