Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Transportation expenditure incurred before contract work was handed to a sub-contractor remained deductible where a memorandum recorded the parties' prior understanding that the assessee would bear that cost. The later execution of the definitive sub-contract did not displace that arrangement, and no duplicate claim by the sub-contractor was alleged; the disallowance was therefore deleted. Labour cess and copy charges deducted from the assessee's contract bills under tender terms were also deductible because the assessee incurred and bore them, their genuineness was undisputed, and the sub-contractor had not claimed them. The related disallowance of sublet expenses was deleted.
Transportation expenditure incurred before contract work was handed to a sub-contractor remained deductible where a memorandum recorded the parties' prior understanding that the assessee would bear that cost. The later execution of the definitive sub-contract did not displace that arrangement, and no duplicate claim by the sub-contractor was alleged; the disallowance was therefore deleted. Labour cess and copy charges deducted from the assessee's contract bills under tender terms were also deductible because the assessee incurred and bore them, their genuineness was undisputed, and the sub-contractor had not claimed them. The related disallowance of sublet expenses was deleted.
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