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...
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The assessee bank made provisions for group gratuity and leave encashment by debiting expenses in its books, but these provisions were never treated as real expenses for income tax purposes. The AO made additions for the difference between the book provisions and actuarial valuations. The ITAT held that the expenses debited pertained to the assessment year and were real expenses, not provisions. The AO's findings that the amounts did not pertain to the year were perverse. Only real income is taxable, not provisions, as held in Shoorji Vallabhdas case. The assessee did not claim notional expenses to reduce profits. The AO's additions were deleted.
The assessee bank made provisions for group gratuity and leave encashment by debiting expenses in its books, but these provisions were never treated as real expenses for income tax purposes. The AO made additions for the difference between the book provisions and actuarial valuations. The ITAT held that the expenses debited pertained to the assessment year and were real expenses, not provisions. The AO's findings that the amounts did not pertain to the year were perverse. Only real income is taxable, not provisions, as held in Shoorji Vallabhdas case. The assessee did not claim notional expenses to reduce profits. The AO's additions were deleted.
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