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...
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Tax was deductible at source on annual lease rent paid to development authorities, and the exemption under section 10(20A) did not apply. Interest for delayed deduction was confined to the period from when tax became deductible until the deductee filed its return. Interest expenditure capitalised as work-in-progress and not charged to the profit and loss account could not be disallowed for delayed tax deduction, because disallowance applies only to expenditure claimed in the profit and loss account. Accordingly, the disallowance of capitalised interest was deleted, while the tax-deduction liability on annual lease rent remained.
Tax was deductible at source on annual lease rent paid to development authorities, and the exemption under section 10(20A) did not apply. Interest for delayed deduction was confined to the period from when tax became deductible until the deductee filed its return. Interest expenditure capitalised as work-in-progress and not charged to the profit and loss account could not be disallowed for delayed tax deduction, because disallowance applies only to expenditure claimed in the profit and loss account. Accordingly, the disallowance of capitalised interest was deleted, while the tax-deduction liability on annual lease rent remained.
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