Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
The ITAT upheld deduction under section 10AA for three SEZ undertakings and for onsite software development profits, and rejected the section 14A disallowance because no exempt income was earned. It also sustained depreciation on goodwill and exclusion of Australian fringe benefit tax from book profit under section 115JB. Foreign tax credit for Japan taxes was allowed, while taxes not eligible for treaty credit were held deductible under section 37(1). The assessee's challenge to allocation of interest cost to section 10AA units failed. Exchange fluctuation was to be split between capital and revenue components, with only the revenue part taxed. Delisting expenses were restored for want of evidence, and prior period expense and foreign tax credit recomputation issues were remanded.
The ITAT upheld deduction under section 10AA for three SEZ undertakings and for onsite software development profits, and rejected the section 14A disallowance because no exempt income was earned. It also sustained depreciation on goodwill and exclusion of Australian fringe benefit tax from book profit under section 115JB. Foreign tax credit for Japan taxes was allowed, while taxes not eligible for treaty credit were held deductible under section 37(1). The assessee's challenge to allocation of interest cost to section 10AA units failed. Exchange fluctuation was to be split between capital and revenue components, with only the revenue part taxed. Delisting expenses were restored for want of evidence, and prior period expense and foreign tax credit recomputation issues were remanded.
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