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 - precondition of applicability of Sec 14A - interest paid on loan / borrowed funds - The tribunal held that the precondition of applicability of Section 14A had not been fulfilled in the present case and that there was no discussion as to how interest payment had been incurred in relation to some exempted income. Therefore, the disallowance made under Section 14A was directed to be deleted. - AT
Disallowance u/s 14A - precondition of applicability of Sec 14A - interest paid on loan / borrowed funds - The tribunal held that the precondition of applicability of Section 14A had not been fulfilled in the present case and that there was no discussion as to how interest payment had been incurred in relation to some exempted income. Therefore, the disallowance made under Section 14A was directed to be deleted. - AT
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