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 14A - profits from shares where held as stock in trade and not as investments - The sum and substance of ratio laid down by the Hon’ble Supreme Court and the Hon’ble High Courts are that in case of banking companies were shares & securities are held as stock in trade, dividend income is considered as business income, and consequently, provisions of Sec. 14A of the Act, cannot be applied. - AT
Disallowance u/s 14A - profits from shares where held as stock in trade and not as investments - The sum and substance of ratio laid down by the Hon’ble Supreme Court and the Hon’ble High Courts are that in case of banking companies were shares & securities are held as stock in trade, dividend income is considered as business income, and consequently, provisions of Sec. 14A of the Act, cannot be applied. - AT
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