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...
Claim of Loss - Deduction u/s. 57 - Taxability of real income / net interest income - The Tribunal observed that the investment in perpetual debt instruments (PDIs) was financed by secured debentures. It was established that the funds raised through debentures were not meant for investment in PDIs but for the objectives of the company. The Tribunal allowed the deduction of interest expenditure against interest income, considering only the net income liable for taxation. - ITAT emphasized that only real income, subject to the provisions of the Act, is taxable.
Claim of Loss - Deduction u/s. 57 - Taxability of real income / net interest income - The Tribunal observed that the investment in perpetual debt instruments (PDIs) was financed by secured debentures. It was established that the funds raised through debentures were not meant for investment in PDIs but for the objectives of the company. The Tribunal allowed the deduction of interest expenditure against interest income, considering only the net income liable for taxation. - ITAT emphasized that only real income, subject to the provisions of the Act, is taxable.
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