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...
Corporate social responsibility donations to institutions approved under section 80G remain eligible for deduction because Explanation 2 to section 37(1) only bars their treatment as business expenditure and does not prohibit section 80G relief. The notes state that the deduction cannot be denied merely because payments also meet CSR obligations, where donations are made through recognised banking channels. Advance-tax interest under section 234C requires factual verification of the liability computation, so the issue was remanded for recomputation if warranted. Refund interest under section 244A likewise depends on verification of relevant dates and may be granted further if admissible.
Corporate social responsibility donations to institutions approved under section 80G remain eligible for deduction because Explanation 2 to section 37(1) only bars their treatment as business expenditure and does not prohibit section 80G relief. The notes state that the deduction cannot be denied merely because payments also meet CSR obligations, where donations are made through recognised banking channels. Advance-tax interest under section 234C requires factual verification of the liability computation, so the issue was remanded for recomputation if warranted. Refund interest under section 244A likewise depends on verification of relevant dates and may be granted further if admissible.
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