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 Appellate Tribunal reviewed a case involving a revision u/s 263 related to deduction u/s 80P(2)(a)(i). The AO allowed interest income from FD investments as a deduction. The Tribunal noted a previous year's treatment by AO as "income from other sources" and rejection of the deduction claim. The CIT(A) later allowed the deduction for the previous year, stating the interest income was part of operational income u/s 80P(2)(a)(i). The Tribunal found the PCIT's revision u/s 263 invalid, as the interest income was deemed part of operational income due to statutory compulsions. The Assessment Order granting the deduction was upheld, and the PCIT's order u/s 263 was quashed. The appeal by the assessee was allowed.
The Appellate Tribunal reviewed a case involving a revision u/s 263 related to deduction u/s 80P(2)(a)(i). The AO allowed interest income from FD investments as a deduction. The Tribunal noted a previous year's treatment by AO as "income from other sources" and rejection of the deduction claim. The CIT(A) later allowed the deduction for the previous year, stating the interest income was part of operational income u/s 80P(2)(a)(i). The Tribunal found the PCIT's revision u/s 263 invalid, as the interest income was deemed part of operational income due to statutory compulsions. The Assessment Order granting the deduction was upheld, and the PCIT's order u/s 263 was quashed. The appeal by the assessee was allowed.
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