Transfer pricing adjustment for software development and related ...

Software Firm Battles Tax Office Over Transfer Pricing, Pay Issues.

Case Laws Income Tax

August 27, 2024

Transfer pricing adjustment for software development and related support services - Comparables deselected due to functional dissimilarity. TPO directed to exclude certain companies. Transfer pricing adjustment for interest on receivables - TPO's calculation of interest on entire closing balance incorrect. TPO instructed to compute interest based on delay for each invoice beyond grace period after examining agreements or market practice. Employee's PF contribution disallowed for non-compliance with statutory deposit timelines. No long-term capital gain on amount credited to capital reserve pursuant to merger, covered u/s 47(vi). Double addition in computation corrected. Finance cost disallowance deleted as no transfer pricing adjustment proposed. Advance tax credit and TDS credit from merged entity directed to be allowed based on evidence.

View Source

← Previous Next →

Transfer pricing adjustment for software development and related ...

Software Firm Battles Tax Office Over Transfer Pricing, Pay Issues.

Case Laws Income Tax

August 27, 2024

You may also like:

This summary discusses various transfer pricing and tax issues. It analyzes whether Advertisement, Marketing and Promotion (AMP) expenses incurred by the assessee were...

The case pertains to service tax liability arising from the sale/transfer of a business as a going concern by way of slump sale under the Income Tax Act, 1961. The issue...

Taxability in the hands of partners v/s firm - transfer of capital asset by firm to partners - There is no merit in the arguments advanced by assessee, that transfer of...

Issues relating to export of computer software Direct tax benefits -Clarification reg. - Circular

Transfer Pricing Adjustments - Purchase of Development Rights - capital transactions and their treatment - The tribunal addressed several crucial issues regarding the...

Service tax liability on sale of imported tally software was disputed. Appellant was a distributor marketing and installing the software on behalf of the seller holding...

With the passage of time where India is becoming a global commercial hub with the advent of Multinational Companies new transfer pricing issues are thrown up and keeping...

TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...

Recovery of short paid service tax - Construction of Complex Service - adjustment of the excess service tax paid - Service Tax when introduced followed the receipt based...

Transfer Pricing (TP) adjustments - Transfer Pricing (TP) adjustments - debar of deduction u/s 10A on addition income assessed u/s 92CD as per the Proviso to 92C(4) -...

The Assessee paid royalty to non-UK entities without entering into an Advance Pricing Agreement (APA) or Mutual Agreement Procedure (MAP) proceedings for the assessment...

Rollback of an Advance Pricing Agreement - Income-tax (Third Amendment) Rules, 2015 - CBDT issues Notification

Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to...

The central issue revolved around whether the movement of goods from manufacturing units in Rajasthan to depots in Bihar and Jharkhand constituted inter-state supply of...

The High Court examined whether the respondents had sufficient material to transfer the petitioners' case from Coimbatore to the Central Circle in Kolkata. The...

Quick Updates: