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...
Marketing expenditure supported only by self-made vouchers may be disallowed where third-party evidence is absent, but a complete disallowance may be inappropriate when the expenditure is modest relative to turnover, relates to client visits and outstation costs, and audited books contain no adverse comments. The discussion notes that a restricted disallowance was sustained. It further explains that insufficient substantiation of an expenditure claim does not itself establish misreporting under section 270A unless a statutory category, such as misrepresentation, suppression of facts, lack of evidence, or a false book entry, is identified. The related misreporting penalty was deleted.
Marketing expenditure supported only by self-made vouchers may be disallowed where third-party evidence is absent, but a complete disallowance may be inappropriate when the expenditure is modest relative to turnover, relates to client visits and outstation costs, and audited books contain no adverse comments. The discussion notes that a restricted disallowance was sustained. It further explains that insufficient substantiation of an expenditure claim does not itself establish misreporting under section 270A unless a statutory category, such as misrepresentation, suppression of facts, lack of evidence, or a false book entry, is identified. The related misreporting penalty was deleted.
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