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 ITAT partly allowed the assessee's appeal. Travel expenses were partly disallowed by 30% considering personal element, while 70% were allowed as business expenses due to lack of documentary evidence establishing exclusive business purpose. Unexplained cash credits u/s 68 were confirmed as the assessee failed to prove identity, creditworthiness, and genuineness of transactions. Disallowance u/s 36(1)(va) for delayed PF/ESIC contributions was upheld following jurisdictional High Court's decision. However, disallowance u/s 36(1)(iii) for interest was deleted as the assessee demonstrated availability of sufficient interest-free funds.
The ITAT partly allowed the assessee's appeal. Travel expenses were partly disallowed by 30% considering personal element, while 70% were allowed as business expenses due to lack of documentary evidence establishing exclusive business purpose. Unexplained cash credits u/s 68 were confirmed as the assessee failed to prove identity, creditworthiness, and genuineness of transactions. Disallowance u/s 36(1)(va) for delayed PF/ESIC contributions was upheld following jurisdictional High Court's decision. However, disallowance u/s 36(1)(iii) for interest was deleted as the assessee demonstrated availability of sufficient interest-free funds.
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