Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Provision for a society Cadre Fund was held deductible as business expenditure under section 37 because it constituted a present obligation under AS 29, with probable outflow and reliable estimation, and therefore was not a contingent liability. Applying Bharat Earth Movers, the Tribunal held that a business liability once incurred and reasonably estimable remains deductible even if discharged later. The Tribunal also relied on consistent accounting treatment, prior departmental acceptance, and coordinate-bench precedents on identical facts, and found the disallowance unsustainable. The addition was directed to be deleted.
Provision for a society Cadre Fund was held deductible as business expenditure under section 37 because it constituted a present obligation under AS 29, with probable outflow and reliable estimation, and therefore was not a contingent liability. Applying Bharat Earth Movers, the Tribunal held that a business liability once incurred and reasonably estimable remains deductible even if discharged later. The Tribunal also relied on consistent accounting treatment, prior departmental acceptance, and coordinate-bench precedents on identical facts, and found the disallowance unsustainable. The addition was directed to be deleted.
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