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...
Omission of clause (i) of section 92BA was treated as having retrospective effect, so the reference to the TPO and the transfer pricing adjustment based on specified domestic transactions was held invalid and deleted. Brokerage paid in the ordinary course of a leasing business was allowed under section 37(1) to the extent supported by invoices and tenant details, while the balance was remitted for verification. Receipts such as car parking income, interest on fixed deposits, permission charges and licence fee were held to have a direct nexus with SEZ business and were treated as eligible for deduction under section 80IAB, making their reclassification as income from other sources unsustainable.
Omission of clause (i) of section 92BA was treated as having retrospective effect, so the reference to the TPO and the transfer pricing adjustment based on specified domestic transactions was held invalid and deleted. Brokerage paid in the ordinary course of a leasing business was allowed under section 37(1) to the extent supported by invoices and tenant details, while the balance was remitted for verification. Receipts such as car parking income, interest on fixed deposits, permission charges and licence fee were held to have a direct nexus with SEZ business and were treated as eligible for deduction under section 80IAB, making their reclassification as income from other sources unsustainable.
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