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...
Expenditure is disallowable under Explanation 1 to section 37(1) only where it is shown to relate to an offence or an act prohibited by law; because no punitive action had been taken by the competent insurance regulator, the disallowance was deleted. For insurance business income, section 44 with the First Schedule provides a special computation regime that overrides the general computation rules, so section 14A read with Rule 8D does not apply to an insurer. The prior co-ordinate bench view in the assessee's own case was followed.
Expenditure is disallowable under Explanation 1 to section 37(1) only where it is shown to relate to an offence or an act prohibited by law; because no punitive action had been taken by the competent insurance regulator, the disallowance was deleted. For insurance business income, section 44 with the First Schedule provides a special computation regime that overrides the general computation rules, so section 14A read with Rule 8D does not apply to an insurer. The prior co-ordinate bench view in the assessee's own case was followed.
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