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...
Selection of a notice under section 143(2) for limited scrutiny was valid because it targeted verification of a claim for deduction, and that ground of appeal was dismissed. The assessees' claim for deduction under 80P as a members' credit cooperative society was sustained by reliance on High Court precedents; the AO is directed to allow the deduction. Interest income derived from providing credit to members should be treated as business income and allowed as a deduction under the cooperative-deduction head rather than under an alternate head; AO is directed to grant deduction accordingly. Accounting provisions for interest and mandated provisioning for non performing advances comply with accrual accounting and statutory mandates, and related disallowances are deleted.
Selection of a notice under section 143(2) for limited scrutiny was valid because it targeted verification of a claim for deduction, and that ground of appeal was dismissed. The assessees' claim for deduction under 80P as a members' credit cooperative society was sustained by reliance on High Court precedents; the AO is directed to allow the deduction. Interest income derived from providing credit to members should be treated as business income and allowed as a deduction under the cooperative-deduction head rather than under an alternate head; AO is directed to grant deduction accordingly. Accounting provisions for interest and mandated provisioning for non performing advances comply with accrual accounting and statutory mandates, and related disallowances are deleted.
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