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...
Disallowance being 10% of expenditure - Disallowance of expenditure @ 10% of the expenditure in the instant case appears to be on the higher side since it gives a profit rate of 37.78% which is not possible in the line of business. Considering the fact that the assessee has already declared profit rate of 9.29%, the disallowance on lumpsum basis in the instant case, in our opinion, meet the ends of justice. - AT
Disallowance being 10% of expenditure - Disallowance of expenditure @ 10% of the expenditure in the instant case appears to be on the higher side since it gives a profit rate of 37.78% which is not possible in the line of business. Considering the fact that the assessee has already declared profit rate of 9.29%, the disallowance on lumpsum basis in the instant case, in our opinion, meet the ends of justice. - AT
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