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...
Coffee hulling and curing charges incurred to process raw coffee beans into marketable coffee were held allowable as business expenditure under section 37(1) because the assessee produced ledger extracts, invoices and bank statements, and the work formed part of its regular business activity; the disallowance as unexplained expenditure was therefore deleted. The Tribunal also rejected the ad hoc 25% disallowance of agricultural expenses, noting supporting bills, vouchers, bank statements, cash details and regular books for diesel, fertiliser, pesticide, labour, transportation and related interest costs, with no specific unsupported item identified by the Revenue. The appeal was partly allowed and both disallowances were deleted.
Coffee hulling and curing charges incurred to process raw coffee beans into marketable coffee were held allowable as business expenditure under section 37(1) because the assessee produced ledger extracts, invoices and bank statements, and the work formed part of its regular business activity; the disallowance as unexplained expenditure was therefore deleted. The Tribunal also rejected the ad hoc 25% disallowance of agricultural expenses, noting supporting bills, vouchers, bank statements, cash details and regular books for diesel, fertiliser, pesticide, labour, transportation and related interest costs, with no specific unsupported item identified by the Revenue. The appeal was partly allowed and both disallowances were deleted.
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