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...
The ITAT Raipur ruled on disallowance u/s 14A r.w.r. 8D regarding expenditure on exempt income. The assessee argued that no disallowance of interest expenditure claimed as deduction was warranted as it had sufficient self-owned funds for exempt income investments. The AO mechanically applied Rule 8D(2)(ii) for disallowance without proper satisfaction on the claim. The AO's general observations did not meet the legal requirement for a valid determination. The tribunal set aside the CIT(A)'s decision to uphold the disallowance, ruling in favor of the assessee due to the AO's failure to meet statutory obligations in assessing the claim.
The ITAT Raipur ruled on disallowance u/s 14A r.w.r. 8D regarding expenditure on exempt income. The assessee argued that no disallowance of interest expenditure claimed as deduction was warranted as it had sufficient self-owned funds for exempt income investments. The AO mechanically applied Rule 8D(2)(ii) for disallowance without proper satisfaction on the claim. The AO's general observations did not meet the legal requirement for a valid determination. The tribunal set aside the CIT(A)'s decision to uphold the disallowance, ruling in favor of the assessee due to the AO's failure to meet statutory obligations in assessing the claim.
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