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...
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Revision u/s 263 by CIT - Regarding the claim of the revenue that, no deduction is allowable u/s 92C(4) of the Act - The claim under Section 10A is not enhanced on account of transfer pricing addition and since the Assessee is not claimed deduction u/s 10A on enhanced assessed income and therefore the proviso to Section 92C(4) shall not apply. - AT
Revision u/s 263 by CIT - Regarding the claim of the revenue that, no deduction is allowable u/s 92C(4) of the Act - The claim under Section 10A is not enhanced on account of transfer pricing addition and since the Assessee is not claimed deduction u/s 10A on enhanced assessed income and therefore the proviso to Section 92C(4) shall not apply. - AT
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