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...
Allowability of interest on Compulsorily Convertible Debentures (CCDs) for period before conversion - RBI policy of FDI is governed by future repayment obligation and CCDs does not have any repayment obligation, hence considered by RBI as equity for FDI policy - CCDs holder neither eligible to voting nor dividend till its conversion hence CCDs are to be considered as Debt only and interest is allowable u/s 36 (1)(iii)
Allowability of interest on Compulsorily Convertible Debentures (CCDs) for period before conversion - RBI policy of FDI is governed by future repayment obligation and CCDs does not have any repayment obligation, hence considered by RBI as equity for FDI policy - CCDs holder neither eligible to voting nor dividend till its conversion hence CCDs are to be considered as Debt only and interest is allowable u/s 36 (1)(iii)
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