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...
Shared support cost allocated by a group company was deductible under section 37(1) because the assessee showed actual receipt of services, business benefit, and a reasonable allocation basis. The Tribunal held that disallowance based only on the fact that the expense was centrally incurred and cross-charged was not sustainable, absent concrete material showing the claim was sham, fictitious, inflated, capital, personal, or otherwise inadmissible. Allocation on a workstation basis was treated as a rational and business-oriented key with direct nexus to operations, and no one-to-one correlation of every pooled cost item was required. The addition was deleted.
Shared support cost allocated by a group company was deductible under section 37(1) because the assessee showed actual receipt of services, business benefit, and a reasonable allocation basis. The Tribunal held that disallowance based only on the fact that the expense was centrally incurred and cross-charged was not sustainable, absent concrete material showing the claim was sham, fictitious, inflated, capital, personal, or otherwise inadmissible. Allocation on a workstation basis was treated as a rational and business-oriented key with direct nexus to operations, and no one-to-one correlation of every pooled cost item was required. The addition was deleted.
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