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 of interest u/s 36(1)(iii) - assessee has a stake in the performance and profit making of wholly owned subsidiaries - it cannot be denied that the advancement of loan is in connection with assessee’s business - the difference in the interest rate between the borrowed funds and loans advanced is only 3.25% and the advanced of loan in connection with its business - no disallowance
Disallowance of interest u/s 36(1)(iii) - assessee has a stake in the performance and profit making of wholly owned subsidiaries - it cannot be denied that the advancement of loan is in connection with assessee’s business - the difference in the interest rate between the borrowed funds and loans advanced is only 3.25% and the advanced of loan in connection with its business - no disallowance
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