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...
Software license expenses incurred by the assessee were held to be revenue expenditure based on the coordinate bench's decision in DCIT v/s M/s First Advantage Private Limited for the preceding year. Regarding disallowance u/s 40(a)(ia), the assessee admitted deducting TDS at a lower rate on Rs. 98,363 and offered 30% of this amount for disallowance. The CIT(A) rightly deleted the disallowance made by the AO, as the assessee had already disallowed 30% of the relevant payments. The ITAT affirmed the CIT(A)'s order on this issue.
Software license expenses incurred by the assessee were held to be revenue expenditure based on the coordinate bench's decision in DCIT v/s M/s First Advantage Private Limited for the preceding year. Regarding disallowance u/s 40(a)(ia), the assessee admitted deducting TDS at a lower rate on Rs. 98,363 and offered 30% of this amount for disallowance. The CIT(A) rightly deleted the disallowance made by the AO, as the assessee had already disallowed 30% of the relevant payments. The ITAT affirmed the CIT(A)'s order on this issue.
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