Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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The ITAT Hyderabad upheld the estimation of income and profit, dismissing Revenue's appeal. The profit was modified to 11.5%. Deduction u/s 80-IA(4) was disallowed based on precedent. Disallowance of interest u/s 14A r.w.r 8D and section 36(1)(iii) was rejected due to business exigency. Interest earned on FDs was not taxed as it was already reduced from finance charges. Cash payments u/s 40A(3) were justified due to lack of banking facilities at remote sites. Business promotion expenses were allowed as connected to business promotion, given income estimation. The findings of CIT(A) were upheld, and Revenue's appeal was dismissed.
The ITAT Hyderabad upheld the estimation of income and profit, dismissing Revenue's appeal. The profit was modified to 11.5%. Deduction u/s 80-IA(4) was disallowed based on precedent. Disallowance of interest u/s 14A r.w.r 8D and section 36(1)(iii) was rejected due to business exigency. Interest earned on FDs was not taxed as it was already reduced from finance charges. Cash payments u/s 40A(3) were justified due to lack of banking facilities at remote sites. Business promotion expenses were allowed as connected to business promotion, given income estimation. The findings of CIT(A) were upheld, and Revenue's appeal was dismissed.
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