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...
Interest earned by a co-operative society from investments with a co-operative bank was treated as eligible for deduction under section 80P(2)(d), following earlier non-jurisdictional precedent. Where conflicting non-jurisdictional High Court views exist, the view favourable to the assessee was preferred. Reliance on Totgars was not accepted to deny the claim in this context. The disallowance was deleted in principle, but the Assessing Officer was asked to verify the actual nature of the interest and then grant consequential relief.
Interest earned by a co-operative society from investments with a co-operative bank was treated as eligible for deduction under section 80P(2)(d), following earlier non-jurisdictional precedent. Where conflicting non-jurisdictional High Court views exist, the view favourable to the assessee was preferred. Reliance on Totgars was not accepted to deny the claim in this context. The disallowance was deleted in principle, but the Assessing Officer was asked to verify the actual nature of the interest and then grant consequential relief.
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