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...
Disallowance under the cash-payment restriction was contested for director remuneration; the tribunal examined ledger entries and found no single-day cash payment exceeding the statutory cash threshold because salaries were paid monthly. The legal basis addressed was whether cash disbursements contravened the prohibition on large cash payments to related parties; finding no violation, the tribunal held the disallowance unjustified and allowed the claim in favour of the taxpayer.
Disallowance under the cash-payment restriction was contested for director remuneration; the tribunal examined ledger entries and found no single-day cash payment exceeding the statutory cash threshold because salaries were paid monthly. The legal basis addressed was whether cash disbursements contravened the prohibition on large cash payments to related parties; finding no violation, the tribunal held the disallowance unjustified and allowed the claim in favour of the taxpayer.
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