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...
The Tribunal restricted disallowance for a political donation deduction to the amount actually shown in the assessee's bank records, holding that a higher figure had no factual basis. It also sustained deletion of the section 69A addition for a bank time deposit, accepting that the deposit was made from disclosed salary income and that the Revenue produced no rebuttal. In respect of gratuity, leave encashment and employee allowance receipts reflected in Form 16, the Tribunal upheld the relief granted because the appellate findings were clear and remained unchallenged. The Revenue's appeal was dismissed.
The Tribunal restricted disallowance for a political donation deduction to the amount actually shown in the assessee's bank records, holding that a higher figure had no factual basis. It also sustained deletion of the section 69A addition for a bank time deposit, accepting that the deposit was made from disclosed salary income and that the Revenue produced no rebuttal. In respect of gratuity, leave encashment and employee allowance receipts reflected in Form 16, the Tribunal upheld the relief granted because the appellate findings were clear and remained unchallenged. The Revenue's appeal was dismissed.
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