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 u/s 40(a)(ia) for non-deduction of tax at source (TDS) - assessee in default - Assessee has paid interest u/s 201(1A) for non-deduction/short deduction of tax - the assessee having paid the interest, the assessee cannot be construed as an assessee in default. Therefore, the provision of Section 40(a)(ia) cannot be applied in assessee’s case. - AT
Disallowance u/s 40(a)(ia) for non-deduction of tax at source (TDS) - assessee in default - Assessee has paid interest u/s 201(1A) for non-deduction/short deduction of tax - the assessee having paid the interest, the assessee cannot be construed as an assessee in default. Therefore, the provision of Section 40(a)(ia) cannot be applied in assessee’s case. - AT
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