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...
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Section 251(1) enhancement power was confined to matters or sources of income considered by the Assessing Officer; the CIT(A) could not introduce a fresh issue by reducing work-in-progress on a point never examined in assessment, so the enhancement was invalid and reversed. Receipts under the joint development arrangement were treated as security deposits and business receipts, not loans or advances, and deemed dividend under section 2(22)(e) could be taxed only in the hands of a shareholder; as the assessee was neither a registered nor beneficial shareholder, the addition was deleted. For the joint development agreement, the asset was stock-in-trade and income had to be measured by the consideration actually receivable under the arrangement, not by stamp duty value of the entire land parcel, so the protective addition for alleged extra consideration was affirmed as deleted.
Section 251(1) enhancement power was confined to matters or sources of income considered by the Assessing Officer; the CIT(A) could not introduce a fresh issue by reducing work-in-progress on a point never examined in assessment, so the enhancement was invalid and reversed. Receipts under the joint development arrangement were treated as security deposits and business receipts, not loans or advances, and deemed dividend under section 2(22)(e) could be taxed only in the hands of a shareholder; as the assessee was neither a registered nor beneficial shareholder, the addition was deleted. For the joint development agreement, the asset was stock-in-trade and income had to be measured by the consideration actually receivable under the arrangement, not by stamp duty value of the entire land parcel, so the protective addition for alleged extra consideration was affirmed as deleted.
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