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...
Claim of depreciation - capitalisation being pre-commencement rent and other expenditure incurred - Section 32 of the Act allows depreciation on actual cost of the asset, which means the actual cost to the assessee. This cost should be construed in ordinarily commercial manner. AS-10 regarding "accounting for fixed assets" issued by the ICAI specifies the components of cost of a fixed asset. - the expenses incurred by the assessee are required to be capitalised - Claim allowed - AT
Claim of depreciation - capitalisation being pre-commencement rent and other expenditure incurred - Section 32 of the Act allows depreciation on actual cost of the asset, which means the actual cost to the assessee. This cost should be construed in ordinarily commercial manner. AS-10 regarding "accounting for fixed assets" issued by the ICAI specifies the components of cost of a fixed asset. - the expenses incurred by the assessee are required to be capitalised - Claim allowed - AT
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