Overlapping GST proceedings require Central and State authorities to designate one competent authority for coordinated adjudication of the same matter...
Composite healthcare supplies retain exemption when patient care is the contract's essential character, despite payment through an implementing agency...
Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Performance guarantee and product warranty obligations were held...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment already covered delay.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Performance guarantee and product warranty obligations were held to be intrinsically linked to the software licensing and maintenance transaction, because the assessee was contractually responsible for updates, upgrades, maintenance and related services; the Tribunal therefore deleted the transfer pricing adjustment, also noting consistency with the assessee's own earlier year. Interest on overdue receivables was likewise deleted because the assessee had already applied TNMM with a working capital adjustment, the delay in collection was factored into the comparables analysis, and a further notional interest imputation would amount to duplication. The Tribunal found no material showing a disguised loan arrangement and accepted the explanation for delayed realisation.
Performance guarantee and product warranty obligations were held to be intrinsically linked to the software licensing and maintenance transaction, because the assessee was contractually responsible for updates, upgrades, maintenance and related services; the Tribunal therefore deleted the transfer pricing adjustment, also noting consistency with the assessee's own earlier year. Interest on overdue receivables was likewise deleted because the assessee had already applied TNMM with a working capital adjustment, the delay in collection was factored into the comparables analysis, and a further notional interest imputation would amount to duplication. The Tribunal found no material showing a disguised loan arrangement and accepted the explanation for delayed realisation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
