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...
Disallowance u/s 14A(2) r.w.r. 8D(2)(ii) - expenditure will have to be excluded from the expenses to be allocated under rule 8D(2)(ii) - entire transaction of borrowing and landing is completely a back to back transaction - Just because it is routed through the same bank account, it cannot be presumed that the money is out of the common funds - AT
Disallowance u/s 14A(2) r.w.r. 8D(2)(ii) - expenditure will have to be excluded from the expenses to be allocated under rule 8D(2)(ii) - entire transaction of borrowing and landing is completely a back to back transaction - Just because it is routed through the same bank account, it cannot be presumed that the money is out of the common funds - AT
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