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...
Foreign-currency loan interest must be benchmarked against the relevant currency's LIBOR-based rate, not domestic lending rates; the interest adjustment was deleted. Corporate guarantees were treated as international transactions, but commission was restricted to 0.50% of outstanding guarantees. For section 10A, separately claimed units require factual examination as independent undertakings, while exclusions from export turnover must also be excluded from total turnover. Exempt-income disallowance excludes interest where interest-free funds exceed investments, with administrative expenditure limited to investments yielding exempt income. Hedging losses on export-related forward contracts were treated as non-speculative revenue losses. Several issues, including BPO benchmarking, software licences, creditor balances, TDS credit, surplus-fund income and foreign tax credit, required verification or fresh examination.
Foreign-currency loan interest must be benchmarked against the relevant currency's LIBOR-based rate, not domestic lending rates; the interest adjustment was deleted. Corporate guarantees were treated as international transactions, but commission was restricted to 0.50% of outstanding guarantees. For section 10A, separately claimed units require factual examination as independent undertakings, while exclusions from export turnover must also be excluded from total turnover. Exempt-income disallowance excludes interest where interest-free funds exceed investments, with administrative expenditure limited to investments yielding exempt income. Hedging losses on export-related forward contracts were treated as non-speculative revenue losses. Several issues, including BPO benchmarking, software licences, creditor balances, TDS credit, surplus-fund income and foreign tax credit, required verification or fresh examination.
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