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...
Section 43CA applies only to transfer of land or building or both held as stock-in-trade, and its deeming fiction cannot be extended to TDR/FSI rights. Because transferable development rights are intangible development rights and not land or building per se, adoption of stamp duty value for their transfer was held impermissible. The addition made under section 43CA was therefore deleted, and the Revenue's appeal failed.
Section 43CA applies only to transfer of land or building or both held as stock-in-trade, and its deeming fiction cannot be extended to TDR/FSI rights. Because transferable development rights are intangible development rights and not land or building per se, adoption of stamp duty value for their transfer was held impermissible. The addition made under section 43CA was therefore deleted, and the Revenue's appeal failed.
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