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...
Declaration under the Income Declaration Scheme was held void for failure to pay tax, surcharge and penalty within the statutory time, rendering the declaration deemed never made and making the undeclared amount chargeable in the previous year (FY 2016-17) under the deeming provision; because the assessee failed to satisfactorily explain the source, the AO's addition as unexplained investment was upheld. The amended higher tax rate was held non-retrospective, so tax on the addition must be computed at the earlier 30% rate rather than the later 60% rate, resulting in a partly allowed outcome.
Declaration under the Income Declaration Scheme was held void for failure to pay tax, surcharge and penalty within the statutory time, rendering the declaration deemed never made and making the undeclared amount chargeable in the previous year (FY 2016-17) under the deeming provision; because the assessee failed to satisfactorily explain the source, the AO's addition as unexplained investment was upheld. The amended higher tax rate was held non-retrospective, so tax on the addition must be computed at the earlier 30% rate rather than the later 60% rate, resulting in a partly allowed outcome.
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