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...
ITAT allowed the assessee's claim for deduction u/s 80IA for development of infrastructure facilities. It held that merely entering into an agreement with the government or receiving payments from it does not disentitle the assessee from claiming deduction as a "developer" u/s 80IA(4). The assessee's activities qualified as development of new infrastructure facilities, following precedents. The department failed to distinguish the facts from favorable orders of higher authorities for prior years.
ITAT allowed the assessee's claim for deduction u/s 80IA for development of infrastructure facilities. It held that merely entering into an agreement with the government or receiving payments from it does not disentitle the assessee from claiming deduction as a "developer" u/s 80IA(4). The assessee's activities qualified as development of new infrastructure facilities, following precedents. The department failed to distinguish the facts from favorable orders of higher authorities for prior years.
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