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...
Bad-debt deduction for share-broking client dues may be claimed where outstanding client balances are treated as irrecoverable and written off in the accounts. Under amended section 36(1)(vii), actual irrecoverability need not be established. Continuing transactions or payments by clients do not preclude the claim where the broker follows a consistent settlement pattern under which clients pay agreed amounts and residual balances are written off. Client receivables qualify as debts when brokerage included in those receivables has been taken into account in computing income. The disallowance of the written-off client dues was deleted and the deduction sustained.
Bad-debt deduction for share-broking client dues may be claimed where outstanding client balances are treated as irrecoverable and written off in the accounts. Under amended section 36(1)(vii), actual irrecoverability need not be established. Continuing transactions or payments by clients do not preclude the claim where the broker follows a consistent settlement pattern under which clients pay agreed amounts and residual balances are written off. Client receivables qualify as debts when brokerage included in those receivables has been taken into account in computing income. The disallowance of the written-off client dues was deleted and the deduction sustained.
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