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...
ITAT held that the DVO valuation obtained in a co-owner's case applied equally to the assessee in respect of the same jointly purchased flats. It also treated the Finance Act, 2020 amendment increasing the tolerance band under section 56(2)(x)(b) from 5 per cent to 10 per cent as clarificatory and curative, with retrospective effect. As the difference between the DVO value and the agreed consideration was within that 10 per cent band, no addition was sustainable and the addition under section 56(2)(x)(b) was deleted.
ITAT held that the DVO valuation obtained in a co-owner's case applied equally to the assessee in respect of the same jointly purchased flats. It also treated the Finance Act, 2020 amendment increasing the tolerance band under section 56(2)(x)(b) from 5 per cent to 10 per cent as clarificatory and curative, with retrospective effect. As the difference between the DVO value and the agreed consideration was within that 10 per cent band, no addition was sustainable and the addition under section 56(2)(x)(b) was deleted.
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