Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Section 10B requires separate computation of export profits for each eligible software-export undertaking only to quantify the deduction. That separate computation does not alter the undertaking's profit or loss for computing combined income, nor does it displace the normal rules for inter-source and inter-head set-off and carry forward of losses. Losses of a Section 10B-eligible undertaking may therefore be set off against profits of other undertakings, with any unabsorbed balance carried forward in accordance with law. The contrary denial of set-off was set aside.
Section 10B requires separate computation of export profits for each eligible software-export undertaking only to quantify the deduction. That separate computation does not alter the undertaking's profit or loss for computing combined income, nor does it displace the normal rules for inter-source and inter-head set-off and carry forward of losses. Losses of a Section 10B-eligible undertaking may therefore be set off against profits of other undertakings, with any unabsorbed balance carried forward in accordance with law. The contrary denial of set-off was set aside.
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