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...
A one-day delay in uploading Form 10DA for the additional employment deduction was treated as a procedural lapse, not a substantive defect, because the form was already on record before the section 143(1) intimation. The Tribunal followed co-ordinate Bench rulings that the prescribed form is a compliance requirement for verification, and the claim cannot be denied once the form is available before assessment or intimation. Reliance on Wipro was distinguished as an exemption-case authority, not a deduction-case authority. The disallowance was deleted and the deduction allowed.
A one-day delay in uploading Form 10DA for the additional employment deduction was treated as a procedural lapse, not a substantive defect, because the form was already on record before the section 143(1) intimation. The Tribunal followed co-ordinate Bench rulings that the prescribed form is a compliance requirement for verification, and the claim cannot be denied once the form is available before assessment or intimation. Reliance on Wipro was distinguished as an exemption-case authority, not a deduction-case authority. The disallowance was deleted and the deduction allowed.
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