Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Computer software acquired by the assessee was held to fall within the depreciable block of assets for computers including computer software, so depreciation had to be allowed at that rate and not as a business or commercial right under the intangible asset head. On section 14A read with Rule 8D, the Tribunal accepted the assessee's own disallowance on the facts, noting no dividend income from equity investments and only nominal exempt LLP profit, and restricted the disallowance to the suo motu amount. For MAT under section 115JB, it followed Vireet Investment and held that a Rule 8D disallowance does not enter book profit, so the addition was deleted and interest was to be recomputed consequentially.
Computer software acquired by the assessee was held to fall within the depreciable block of assets for computers including computer software, so depreciation had to be allowed at that rate and not as a business or commercial right under the intangible asset head. On section 14A read with Rule 8D, the Tribunal accepted the assessee's own disallowance on the facts, noting no dividend income from equity investments and only nominal exempt LLP profit, and restricted the disallowance to the suo motu amount. For MAT under section 115JB, it followed Vireet Investment and held that a Rule 8D disallowance does not enter book profit, so the addition was deleted and interest was to be recomputed consequentially.
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