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 alleged excess business loss arose from a clerical computation mismatch between book loss and loss computed under the Act, with no adverse scrutiny finding on the underlying claim, so the disallowance was deleted. It further accepted compensation paid to remove encroachment as a genuine cost of improvement for long-term capital gains computation, noting that the supporting agreements, payment records and verification material showed no serious discrepancy and the lower authorities had rejected the claim only on a general assertion of incomplete details. The indexed cost of improvement was therefore allowed and the appeal succeeded in full.
ITAT held that the alleged excess business loss arose from a clerical computation mismatch between book loss and loss computed under the Act, with no adverse scrutiny finding on the underlying claim, so the disallowance was deleted. It further accepted compensation paid to remove encroachment as a genuine cost of improvement for long-term capital gains computation, noting that the supporting agreements, payment records and verification material showed no serious discrepancy and the lower authorities had rejected the claim only on a general assertion of incomplete details. The indexed cost of improvement was therefore allowed and the appeal succeeded in full.
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