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...
Limited scrutiny cannot be expanded into complete scrutiny without the written approval mandated by CBDT Instruction No. 7/2014; the Tribunal found that the assessment was enlarged beyond the original capital gains issue without such approval, so the assessment was quashed. Section 69A was not barred merely because the share acquisition transactions related to time-barred years, as the Tribunal treated the deeming fiction as sufficient to permit enquiry. For section 54F, exemption cannot be denied solely because the residential property was not conveyed by a registered sale deed; where purchase and investment within the statutory period were shown, the denial was unsustainable. The appeal was allowed.
Limited scrutiny cannot be expanded into complete scrutiny without the written approval mandated by CBDT Instruction No. 7/2014; the Tribunal found that the assessment was enlarged beyond the original capital gains issue without such approval, so the assessment was quashed. Section 69A was not barred merely because the share acquisition transactions related to time-barred years, as the Tribunal treated the deeming fiction as sufficient to permit enquiry. For section 54F, exemption cannot be denied solely because the residential property was not conveyed by a registered sale deed; where purchase and investment within the statutory period were shown, the denial was unsustainable. The appeal was allowed.
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