Export of Wheat Flour and related products subject to online allocation, eligibility criteria, non-transferable six-month authorisations and reporting...
Straight-line lease rental accounting change results in penalty quashed where disclosed accounts and bona fide arguable accounting interpretation exis...
Allocation of enhanced FSI/TDR proceeds between cooperative society and individual flat-owners; tribunal deletes society LTCG addition, remits 80P ver...
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Transfer pricing adjustment for corporate guarantees was governed by precedent in the taxpayer's own case, requiring guarantee commission to be benchmarked at 0.5% per annum for performance, lease and finance guarantees, and the adjustment was restricted accordingly. Overseas "State taxes" were held deductible unless eligible for relief under s. 90, since "tax" in s. 2(43) for s. 40(a)(ii) covers only tax chargeable under the Act; AO was directed to verify treaty relief and allow deduction if none. Payments for imported software were not "royalty" for internal-use software and no TDS was required; contrary treatment for trading software was not sustained. Disallowance under s. 14A r/w r. 8D was deleted for lack of recorded satisfaction; tax sparing credit under India-Singapore DTAA was allowed on FIFO method. - ITAT
Transfer pricing adjustment for corporate guarantees was governed by precedent in the taxpayer's own case, requiring guarantee commission to be benchmarked at 0.5% per annum for performance, lease and finance guarantees, and the adjustment was restricted accordingly. Overseas "State taxes" were held deductible unless eligible for relief under s. 90, since "tax" in s. 2(43) for s. 40(a)(ii) covers only tax chargeable under the Act; AO was directed to verify treaty relief and allow deduction if none. Payments for imported software were not "royalty" for internal-use software and no TDS was required; contrary treatment for trading software was not sustained. Disallowance under s. 14A r/w r. 8D was deleted for lack of recorded satisfaction; tax sparing credit under India-Singapore DTAA was allowed on FIFO method. - ITAT
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