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...
Deduction under Section 80I on the profits and gains of an industrial undertaking had to be computed without first reducing the deduction claimed under Section 32AB. Applying the Supreme Court's distinction between 'profits and gains' and 'income' in Vijay Industries, the Court held that Section 80I is to be worked out on the undertaking's profits themselves, not on a net figure after the 32AB reduction. The Tribunal was therefore wrong to direct such reduction, and the question was answered for the assessee and against the Revenue.
Deduction under Section 80I on the profits and gains of an industrial undertaking had to be computed without first reducing the deduction claimed under Section 32AB. Applying the Supreme Court's distinction between 'profits and gains' and 'income' in Vijay Industries, the Court held that Section 80I is to be worked out on the undertaking's profits themselves, not on a net figure after the 32AB reduction. The Tribunal was therefore wrong to direct such reduction, and the question was answered for the assessee and against the Revenue.
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