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...
DCF share valuation could not be discarded and replaced with another fair market value without first identifying a specific defect or non-compliance in the assessee's prescribed valuation report, so the addition for excess share premium under section 56(2)(vii)(b) was deleted. Protective assessment was confined to cases of doubt about the correct person chargeable to tax; where both additions were made in the same assessee's hands in the same year under different heads, that basis did not apply, so the section 68 protective addition was also deleted. The appeal was allowed.
DCF share valuation could not be discarded and replaced with another fair market value without first identifying a specific defect or non-compliance in the assessee's prescribed valuation report, so the addition for excess share premium under section 56(2)(vii)(b) was deleted. Protective assessment was confined to cases of doubt about the correct person chargeable to tax; where both additions were made in the same assessee's hands in the same year under different heads, that basis did not apply, so the section 68 protective addition was also deleted. The appeal was allowed.
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