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 87A rebate was held to depend on the rate of taxation, not merely the head of income. In a mixed-income case under the new tax regime, the Tribunal found that tax on capital gains chargeable at special rates is computed separately and the rebate cannot be set off against that component. The rebate was therefore confined to the tax attributable to income chargeable at normal rates, including business income and income from other sources. The appeal was partly allowed, and rebate under section 87A was denied against tax on special-rate capital gains.
Section 87A rebate was held to depend on the rate of taxation, not merely the head of income. In a mixed-income case under the new tax regime, the Tribunal found that tax on capital gains chargeable at special rates is computed separately and the rebate cannot be set off against that component. The rebate was therefore confined to the tax attributable to income chargeable at normal rates, including business income and income from other sources. The appeal was partly allowed, and rebate under section 87A was denied against tax on special-rate capital gains.
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