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...
Whether the assessee qualified as an Urban Local Body for exemption under section 10(20) was the primary issue; the Tribunal relied on subsequent assessment-year records showing the Revenue had dropped reassessment proceedings after recording that the assessee qualified as a local authority, treating those administrative actions and available materials as determinative. Applying that principle, the Tribunal held the assessee entitled to exemption and set aside additions made by the AO and affirmed by the CIT(A), deleting the assessed income for the relevant year and granting consequential relief to the assessee.
Whether the assessee qualified as an Urban Local Body for exemption under section 10(20) was the primary issue; the Tribunal relied on subsequent assessment-year records showing the Revenue had dropped reassessment proceedings after recording that the assessee qualified as a local authority, treating those administrative actions and available materials as determinative. Applying that principle, the Tribunal held the assessee entitled to exemption and set aside additions made by the AO and affirmed by the CIT(A), deleting the assessed income for the relevant year and granting consequential relief to the assessee.
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