Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
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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