Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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As the amount paid by the assessee to specific persons are taxed in the hands of specific persons at the same rate , disallowance u/s 40A(2)(b) will be meaningless inasmuch as “permitting the Revenue to tax the same income again at the same rate in the hand of principal payer would amount to double taxation".
As the amount paid by the assessee to specific persons are taxed in the hands of specific persons at the same rate , disallowance u/s 40A(2)(b) will be meaningless inasmuch as “permitting the Revenue to tax the same income again at the same rate in the hand of principal payer would amount to double taxation".
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