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 was entitled to deduction u/s 10A despite receiving foreign exchange beyond six months from the end of the previous year, as the Reserve Bank of India, being the competent authority under the Foreign Exchange Management Act, 1999, had granted approval for realization of export proceeds by the assessee. The HC held that such approval met the requirement of Section 10A(3), entitling the assessee to exemption u/s 10A. The decision was rendered in favor of the assessee, in line with the Bombay HC judgment in Morgan Stanley Advantage Services P. Ltd.
The assessee was entitled to deduction u/s 10A despite receiving foreign exchange beyond six months from the end of the previous year, as the Reserve Bank of India, being the competent authority under the Foreign Exchange Management Act, 1999, had granted approval for realization of export proceeds by the assessee. The HC held that such approval met the requirement of Section 10A(3), entitling the assessee to exemption u/s 10A. The decision was rendered in favor of the assessee, in line with the Bombay HC judgment in Morgan Stanley Advantage Services P. Ltd.
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