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...
Claim for deduction under Section 80-IA is rejected by Revenue because agreement was with a corporate and the fuel farm lay outside airport premises; court finds the agreement was with a statutory airport authority and that the fuel farm is an integral component of airport operations, so the requisite conditions for the 80-IA benefit are satisfied and the deduction is allowable. On interest deductibility under Section 36(1)(iii) for hedge (swap) transactions, the Tribunal's application of the controlling Supreme Court precedent supports allowance of the interest expense, and Revenue does not contest that applicability.
Claim for deduction under Section 80-IA is rejected by Revenue because agreement was with a corporate and the fuel farm lay outside airport premises; court finds the agreement was with a statutory airport authority and that the fuel farm is an integral component of airport operations, so the requisite conditions for the 80-IA benefit are satisfied and the deduction is allowable. On interest deductibility under Section 36(1)(iii) for hedge (swap) transactions, the Tribunal's application of the controlling Supreme Court precedent supports allowance of the interest expense, and Revenue does not contest that applicability.
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