Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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An aborted IPO expenditure was treated as revenue expenditure allowable under section 37(1) because no asset came into existence and no enduring benefit was obtained. Receipts from foreign exchange differences and write-back of provisions were held to have a direct first-degree nexus with the export business of the 100% export-oriented unit, so section 10B deduction was allowed. Product development /expenses were not permitted to be spread as deferred revenue expenditure in the absence of statutory basis. Section 14A disallowance was confined to the exempt income earned. Loss on forward contracts entered into to hedge business exposure was held to be normal business loss, not speculation loss.
An aborted IPO expenditure was treated as revenue expenditure allowable under section 37(1) because no asset came into existence and no enduring benefit was obtained. Receipts from foreign exchange differences and write-back of provisions were held to have a direct first-degree nexus with the export business of the 100% export-oriented unit, so section 10B deduction was allowed. Product development /expenses were not permitted to be spread as deferred revenue expenditure in the absence of statutory basis. Section 14A disallowance was confined to the exempt income earned. Loss on forward contracts entered into to hedge business exposure was held to be normal business loss, not speculation loss.
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