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 Mumbai upheld the disallowance made u/s. 80IA due to the assessee not claiming the deduction u/s. 80IA in response to the return filed u/s. 153A. The AO added bogus purchases, but the CIT(A) confirmed the addition while allowing deduction u/s. 80IA as the purchases were related to business activity. The AO applied gross profit rate to one party's purchases and deemed the other party's transactions as 'bogus,' leading to an increase in business income eligible for u/s. 80IA deduction. The ITAT relied on CBDT Circular No.37 of 2016 and past precedents, affirming the CIT(A)'s decision. The appeal was decided against the revenue.
The ITAT Mumbai upheld the disallowance made u/s. 80IA due to the assessee not claiming the deduction u/s. 80IA in response to the return filed u/s. 153A. The AO added bogus purchases, but the CIT(A) confirmed the addition while allowing deduction u/s. 80IA as the purchases were related to business activity. The AO applied gross profit rate to one party's purchases and deemed the other party's transactions as 'bogus,' leading to an increase in business income eligible for u/s. 80IA deduction. The ITAT relied on CBDT Circular No.37 of 2016 and past precedents, affirming the CIT(A)'s decision. The appeal was decided against the revenue.
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