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...
Belated filing of Form 10CCB did not, by itself, justify denial of deduction under section 80IA where the return was filed in time and the audit report was on record before processing under section 143(1). The Tribunal held that filing Form 10CCB by the due date is a procedural requirement, and once the report was furnished before issuance of the intimation, the CPC was bound to examine it. On that basis, the Commissioner (Appeals)' order allowing the deduction was upheld and the Revenue's challenge to the disallowance failed.
Belated filing of Form 10CCB did not, by itself, justify denial of deduction under section 80IA where the return was filed in time and the audit report was on record before processing under section 143(1). The Tribunal held that filing Form 10CCB by the due date is a procedural requirement, and once the report was furnished before issuance of the intimation, the CPC was bound to examine it. On that basis, the Commissioner (Appeals)' order allowing the deduction was upheld and the Revenue's challenge to the disallowance failed.
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