Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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ITAT remanded the case to the AO for compliance with DRP's directive regarding transfer pricing adjustment. The tribunal acknowledged the DR's concession that the AO had not implemented the prescribed +/- 3% arm's length price adjustment under section 92C(1). The matter was restored to the AO's file to ensure proper application of the DRP's direction, specifically to grant the mandated transfer pricing adjustment within the statutorily defined percentage range.
ITAT remanded the case to the AO for compliance with DRP's directive regarding transfer pricing adjustment. The tribunal acknowledged the DR's concession that the AO had not implemented the prescribed +/- 3% arm's length price adjustment under section 92C(1). The matter was restored to the AO's file to ensure proper application of the DRP's direction, specifically to grant the mandated transfer pricing adjustment within the statutorily defined percentage range.
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