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 40(a)(ia) of Wharfage charges - Wharfage charges paid by assessee are charges which facilitate the loading / unloading of goods at waterfront - no use of land but even if it was held that there is any use of land, then the same was incidental - cannot be equated to be a charge for ‘rent’ for use of water - No TDS u/s 194I - allowed as deduction u/s 37(1)
Disallowance u/s 40(a)(ia) of Wharfage charges - Wharfage charges paid by assessee are charges which facilitate the loading / unloading of goods at waterfront - no use of land but even if it was held that there is any use of land, then the same was incidental - cannot be equated to be a charge for ‘rent’ for use of water - No TDS u/s 194I - allowed as deduction u/s 37(1)
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