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...
A reassessment opened to tax long-term capital gains from a joint development agreement could also entertain a section 54F claim directly linked to that escaped income, because reassessment is not a review of concluded matters but relief bearing on the very income under examination. The Tribunal further held that a landowner's agreed share of residential units to be constructed and allotted by the developer can qualify as investment in construction of a residential house for section 54F purposes, following Karnataka High Court authorities. The exemption claim was therefore restored for fresh adjudication on the remaining statutory conditions.
A reassessment opened to tax long-term capital gains from a joint development agreement could also entertain a section 54F claim directly linked to that escaped income, because reassessment is not a review of concluded matters but relief bearing on the very income under examination. The Tribunal further held that a landowner's agreed share of residential units to be constructed and allotted by the developer can qualify as investment in construction of a residential house for section 54F purposes, following Karnataka High Court authorities. The exemption claim was therefore restored for fresh adjudication on the remaining statutory conditions.
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