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...
Assessee furnished exhaustive entries and supporting documents for professional fees, all subjected to TDS, establishing genuineness of the expenses; therefore the assessing officer's adhoc 50% disallowance was unsustainable and the appellate authority erred in upholding it. On that basis the disallowance was deleted and the assessee's appeal allowed, the decision reversing the earlier finding because documentary proof and TDS deduction negated any reason to doubt the professional charges claimed.
Assessee furnished exhaustive entries and supporting documents for professional fees, all subjected to TDS, establishing genuineness of the expenses; therefore the assessing officer's adhoc 50% disallowance was unsustainable and the appellate authority erred in upholding it. On that basis the disallowance was deleted and the assessee's appeal allowed, the decision reversing the earlier finding because documentary proof and TDS deduction negated any reason to doubt the professional charges claimed.
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