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...
Proportionate allowability of lease premium u/s 37 - it is difficult to appreciate that fact of rent being depressed rent can only be appreciated as such if there is recital about it in the lease rent - substantial amount of money was paid as premium, claimed and shown by assessee to be advance rents and where rents reserved - no hesitation to infer that rents reserved are depressed rents - deduction allowable
Proportionate allowability of lease premium u/s 37 - it is difficult to appreciate that fact of rent being depressed rent can only be appreciated as such if there is recital about it in the lease rent - substantial amount of money was paid as premium, claimed and shown by assessee to be advance rents and where rents reserved - no hesitation to infer that rents reserved are depressed rents - deduction allowable
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