Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Intra-group software licence costs are examined through inter-company invoices, third-party licensing agreements, allocation workings and supporting invoices to establish actual availing and the allocation basis for arm's length pricing. The notes state that a nil arm's length price was not justified where this evidence was furnished. For low-end IS&T services, Dispute Resolution Panel directions require verification of segmental audited revenue and recomputation of operating margins; cost-to-cost IT reimbursements must be treated consistently with those directions. Eclerx Services Ltd. is identified as functionally and operationally incomparable. Reversal of a previously disallowed bonus provision requires verification before deduction, and a pending rectification application must be decided before a fresh order.
Intra-group software licence costs are examined through inter-company invoices, third-party licensing agreements, allocation workings and supporting invoices to establish actual availing and the allocation basis for arm's length pricing. The notes state that a nil arm's length price was not justified where this evidence was furnished. For low-end IS&T services, Dispute Resolution Panel directions require verification of segmental audited revenue and recomputation of operating margins; cost-to-cost IT reimbursements must be treated consistently with those directions. Eclerx Services Ltd. is identified as functionally and operationally incomparable. Reversal of a previously disallowed bonus provision requires verification before deduction, and a pending rectification application must be decided before a fresh order.
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