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...
Flood rehabilitation housing expenditure may qualify as business expenditure where incurred under a State Government memorandum for commercial expediency and long-term business benefit; that issue was remitted for fresh consideration in line with jurisdictional High Court rulings. Ad hoc disallowances of vehicle hire, transport charges and repairs to leasehold premises were deleted because the assessee produced bills, PANs, ledgers and other supporting records, and no objective basis for estimation was shown. Interest reflected in Form 26AS was not taxed on accrual absent reasonable certainty of receipt, and TDS credit was shifted to the year of actual offer. Customs duty liability crystallised on demand and was allowable on payment, infrastructure sharing charges were accepted as business expenditure, and customer advances were not taxed under cessation of liability principles because no remission occurred.
Flood rehabilitation housing expenditure may qualify as business expenditure where incurred under a State Government memorandum for commercial expediency and long-term business benefit; that issue was remitted for fresh consideration in line with jurisdictional High Court rulings. Ad hoc disallowances of vehicle hire, transport charges and repairs to leasehold premises were deleted because the assessee produced bills, PANs, ledgers and other supporting records, and no objective basis for estimation was shown. Interest reflected in Form 26AS was not taxed on accrual absent reasonable certainty of receipt, and TDS credit was shifted to the year of actual offer. Customs duty liability crystallised on demand and was allowable on payment, infrastructure sharing charges were accepted as business expenditure, and customer advances were not taxed under cessation of liability principles because no remission occurred.
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