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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ITAT upheld CIT(A)'s decision, allowing normal deduction u/s 35(1)(iv) for R&D capital expenditure disallowed under weighted deduction u/s 35(2AB). The tribunal found the issue consistent with the assessee's previous year's case, affirming that capital expenditure on scientific research at an approved R&D facility remains deductible even if not qualifying for enhanced deduction. Revenue's appeal grounds were comprehensively dismissed, maintaining the lower appellate authority's reasoning and providing tax relief to the assessee.
ITAT upheld CIT(A)'s decision, allowing normal deduction u/s 35(1)(iv) for R&D capital expenditure disallowed under weighted deduction u/s 35(2AB). The tribunal found the issue consistent with the assessee's previous year's case, affirming that capital expenditure on scientific research at an approved R&D facility remains deductible even if not qualifying for enhanced deduction. Revenue's appeal grounds were comprehensively dismissed, maintaining the lower appellate authority's reasoning and providing tax relief to the assessee.
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