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 exemption u/s 10(23C)(vi) - Allegatin that, assessee Society has continued to divert its funds towards non-educational activities by way of huge advances to RNMCS - Non-charging of interest on the advances given allegation is not relevant in the context of S. 10 (23C) (vi) in as much as there appears no such specific clause/ provision in 15th Proviso or anywhere in S. 10 (23C)(vi) empowering the CIT, or as may be the case u/s 12AA (3) r/w S. 13 (1)(c). - AT
Allowability of exemption u/s 10(23C)(vi) - Allegatin that, assessee Society has continued to divert its funds towards non-educational activities by way of huge advances to RNMCS - Non-charging of interest on the advances given allegation is not relevant in the context of S. 10 (23C) (vi) in as much as there appears no such specific clause/ provision in 15th Proviso or anywhere in S. 10 (23C)(vi) empowering the CIT, or as may be the case u/s 12AA (3) r/w S. 13 (1)(c). - AT
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