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 for donation to a political party under section 80GGC cannot be denied on a bare accommodation-entry allegation unless there is evidence that the donation was returned to the assessee or that the assessee derived a direct benefit from a backdoor arrangement. In the absence of material showing refund of the donation, retention of commission by the party, or any direct nexus between the payment and an advantage to the assessee, the allegation by itself is insufficient to disallow the claim. The deduction was therefore allowed.
Deduction for donation to a political party under section 80GGC cannot be denied on a bare accommodation-entry allegation unless there is evidence that the donation was returned to the assessee or that the assessee derived a direct benefit from a backdoor arrangement. In the absence of material showing refund of the donation, retention of commission by the party, or any direct nexus between the payment and an advantage to the assessee, the allegation by itself is insufficient to disallow the claim. The deduction was therefore allowed.
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