Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Deduction for indexed cost of improvement was allowed in part where documentary proof was incomplete: exercising evaluative discretion, the Tribunal permitted 80% of the improvement cost claimed to be adopted for computing the indexed cost of improvement and directed the assessing officer to recompute and grant the deduction accordingly, setting aside the contrary appellate finding; the Tribunal also condoned the delay in filing the appeal. The operative effect requires the AO to apply 80% of claimed improvement amounts for the specified years and allow corresponding indexed deduction.
Deduction for indexed cost of improvement was allowed in part where documentary proof was incomplete: exercising evaluative discretion, the Tribunal permitted 80% of the improvement cost claimed to be adopted for computing the indexed cost of improvement and directed the assessing officer to recompute and grant the deduction accordingly, setting aside the contrary appellate finding; the Tribunal also condoned the delay in filing the appeal. The operative effect requires the AO to apply 80% of claimed improvement amounts for the specified years and allow corresponding indexed deduction.
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