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...
Safe harbour under Rule 11UA(4) was treated as curative and retrospectively applicable: where the difference between issue price and the prescribed valuation did not exceed 10%, the issue price was deemed to be fair market value, so the section 56(2)(viib) addition on shares issued to the resident shareholder could not survive. Legal and professional charges for due diligence, business evaluation and advisory services connected with structuring and growth were held to be revenue expenditure, because no capital asset or enduring capital advantage was shown; the disallowance was deleted.
Safe harbour under Rule 11UA(4) was treated as curative and retrospectively applicable: where the difference between issue price and the prescribed valuation did not exceed 10%, the issue price was deemed to be fair market value, so the section 56(2)(viib) addition on shares issued to the resident shareholder could not survive. Legal and professional charges for due diligence, business evaluation and advisory services connected with structuring and growth were held to be revenue expenditure, because no capital asset or enduring capital advantage was shown; the disallowance was deleted.
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