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...
In an anti-profiteering inquiry under section 171, tax reduction and input tax credit issues must still be tested against evidence that prices may also be affected by market forces and higher input costs. The Tribunal accepted that any presumption of profiteering is rebuttable and must yield to clear evidence. Because the DGAP acknowledged the respondent's documents but did not meaningfully reconsider them, the report was found unsustainable. The matter was remanded for a fresh investigation from the beginning under Rule 133(4), with liberty to both sides to place further material.
In an anti-profiteering inquiry under section 171, tax reduction and input tax credit issues must still be tested against evidence that prices may also be affected by market forces and higher input costs. The Tribunal accepted that any presumption of profiteering is rebuttable and must yield to clear evidence. Because the DGAP acknowledged the respondent's documents but did not meaningfully reconsider them, the report was found unsustainable. The matter was remanded for a fresh investigation from the beginning under Rule 133(4), with liberty to both sides to place further material.
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