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 of expenses apportioned to rented portions was contested where corresponding recoveries (power charges and CAM/maintenance) were recorded as business income. Applying the matching principle and prior coordinate bench decisions on identical facts, the ITAT held that apportioned power and fuel expenses and proportionate repair and maintenance charges need not be disallowed when recovered from tenants and reflected as business income; accordingly the Tribunal deleted the AO's additions in respect of both categories of expenses.
Disallowance of expenses apportioned to rented portions was contested where corresponding recoveries (power charges and CAM/maintenance) were recorded as business income. Applying the matching principle and prior coordinate bench decisions on identical facts, the ITAT held that apportioned power and fuel expenses and proportionate repair and maintenance charges need not be disallowed when recovered from tenants and reflected as business income; accordingly the Tribunal deleted the AO's additions in respect of both categories of expenses.
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