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...
Duty drawback is specifically governed by section 145B(3), which deems it taxable as income of the previous year in which it is actually received, if not charged in an earlier year. Applying that statutory rule, the Tribunal held that taxing sanctioned duty drawback on an accrual basis during the year under consideration was unsustainable, even though the assessee followed the mercantile system. The addition was deleted and the appeal was allowed.
Duty drawback is specifically governed by section 145B(3), which deems it taxable as income of the previous year in which it is actually received, if not charged in an earlier year. Applying that statutory rule, the Tribunal held that taxing sanctioned duty drawback on an accrual basis during the year under consideration was unsustainable, even though the assessee followed the mercantile system. The addition was deleted and the appeal was allowed.
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