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...
A genuine donation made by cheque to an approved institution remained substantively eligible for deduction, and the claim could not be refused merely because the wrong deduction provision was quoted. The Tribunal held that a technical misdescription of the provision did not defeat relief where the facts already on record established eligibility and allowing the claim under the correct provision caused no adverse effect on total income. It also recognised that appellate authority could grant the proper relief on the existing material, so the disallowance was unsustainable and was directed to be deleted.
A genuine donation made by cheque to an approved institution remained substantively eligible for deduction, and the claim could not be refused merely because the wrong deduction provision was quoted. The Tribunal held that a technical misdescription of the provision did not defeat relief where the facts already on record established eligibility and allowing the claim under the correct provision caused no adverse effect on total income. It also recognised that appellate authority could grant the proper relief on the existing material, so the disallowance was unsustainable and was directed to be deleted.
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