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...
Compensation received on compulsory acquisition of agricultural land under the National Highways Act was held to be exempt from tax. Although the assessee had wrongly reflected the receipt as exempt agricultural income, the Tribunal accepted the award and payment records showing that the amount represented statutory land acquisition compensation with interest. The authorities had already treated the interest component as exempt, but wrongly assessed the compensation component as income from other sources. Relying on CBDT Circular No. 36 of 2016, section 96 of the RFCTLARR Act, and the decisions in Sanjay Kumar Baid and NHAI v. P. Nagaraju, the Tribunal held that the exemption extended to acquisition under the National Highways Act and deleted the addition.
Compensation received on compulsory acquisition of agricultural land under the National Highways Act was held to be exempt from tax. Although the assessee had wrongly reflected the receipt as exempt agricultural income, the Tribunal accepted the award and payment records showing that the amount represented statutory land acquisition compensation with interest. The authorities had already treated the interest component as exempt, but wrongly assessed the compensation component as income from other sources. Relying on CBDT Circular No. 36 of 2016, section 96 of the RFCTLARR Act, and the decisions in Sanjay Kumar Baid and NHAI v. P. Nagaraju, the Tribunal held that the exemption extended to acquisition under the National Highways Act and deleted the addition.
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