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...
Profits of the SEZ manufacturing unit were excluded from book profit for AY 2011-12 because the withdrawal of the MAT exclusion operated prospectively from 1 April 2012. Disallowance under section 14A was confined to the amount of exempt income. Claims for deduction under section 10AA on alleged SEZ trading and manufacturing activities failed because the assessee did not produce credible evidence that the eligible operations were actually carried on, and exemption conditions had to be strictly proved. The Tribunal also upheld additions for cessation of trading liability under section 41(1) and unexplained sundry creditors under section 68 for want of proof of subsisting liabilities, identity, creditworthiness and genuineness.
Profits of the SEZ manufacturing unit were excluded from book profit for AY 2011-12 because the withdrawal of the MAT exclusion operated prospectively from 1 April 2012. Disallowance under section 14A was confined to the amount of exempt income. Claims for deduction under section 10AA on alleged SEZ trading and manufacturing activities failed because the assessee did not produce credible evidence that the eligible operations were actually carried on, and exemption conditions had to be strictly proved. The Tribunal also upheld additions for cessation of trading liability under section 41(1) and unexplained sundry creditors under section 68 for want of proof of subsisting liabilities, identity, creditworthiness and genuineness.
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