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...
DSIR-certified capital scientific research expenditure qualified for weighted deduction at 200%, and the Tribunal directed allowance of the balance deduction where only 100% had been given on the certified amount. For uncertified capital expenditure, it held that once the expenditure was actually incurred for scientific research and that fact was undisputed, denial of weighted deduction did not bar a normal deduction under section 35(1)(iv); the Assessing Officer was directed to verify and allow it. On transfer pricing, the deletion of the adjustment was sustained because no defect was shown in the assessee's study, third-party finished-goods margins were not a proper benchmark for inter-unit transfers, and no fresh material distinguished the year from earlier years. The consequential section 80IC relief was also upheld.
DSIR-certified capital scientific research expenditure qualified for weighted deduction at 200%, and the Tribunal directed allowance of the balance deduction where only 100% had been given on the certified amount. For uncertified capital expenditure, it held that once the expenditure was actually incurred for scientific research and that fact was undisputed, denial of weighted deduction did not bar a normal deduction under section 35(1)(iv); the Assessing Officer was directed to verify and allow it. On transfer pricing, the deletion of the adjustment was sustained because no defect was shown in the assessee's study, third-party finished-goods margins were not a proper benchmark for inter-unit transfers, and no fresh material distinguished the year from earlier years. The consequential section 80IC relief was also upheld.
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