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...
Claimed royalty for use of a logo was held deductible under the business expenditure test because the assessee produced the agreement and evidence and the payment was established as wholly and exclusively for business, so the royalty addition was deleted. An addition for undervaluation of closing stock was disallowed applying the consistency principle in stock valuation and tax neutrality of corresponding opening stock adjustments, because the assessee consistently excluded freight as in prior years. A capital subsidy granted as an industrial incentive was not required to be reduced from asset cost under the cited cost-reduction exception, so the related addition was deleted.
Claimed royalty for use of a logo was held deductible under the business expenditure test because the assessee produced the agreement and evidence and the payment was established as wholly and exclusively for business, so the royalty addition was deleted. An addition for undervaluation of closing stock was disallowed applying the consistency principle in stock valuation and tax neutrality of corresponding opening stock adjustments, because the assessee consistently excluded freight as in prior years. A capital subsidy granted as an industrial incentive was not required to be reduced from asset cost under the cited cost-reduction exception, so the related addition was deleted.
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