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...
Assessee's liability to collect and deposit TCS on scrap was examined on the basis of filed Form 27EQ returns, quarterly acknowledgements and a reconciliation matching scrap sales in TCS returns with audited accounts; the tribunal accepted a detailed quarterly summary showing TCS collected and adjustments (including roll-scrap treated as asset sale and duties/taxes) and held that these documentary reconciliations established collection and deposit of TCS. Operative effect: the assessment officer's imposition of additional TCS liability was found unsustainable and the order levying extra TCS was set aside.
Assessee's liability to collect and deposit TCS on scrap was examined on the basis of filed Form 27EQ returns, quarterly acknowledgements and a reconciliation matching scrap sales in TCS returns with audited accounts; the tribunal accepted a detailed quarterly summary showing TCS collected and adjustments (including roll-scrap treated as asset sale and duties/taxes) and held that these documentary reconciliations established collection and deposit of TCS. Operative effect: the assessment officer's imposition of additional TCS liability was found unsustainable and the order levying extra TCS was set aside.
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