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...
Deduction under section 80G was allowed for donations forming part of CSR expenditure because disallowance under Explanation 2 to section 37(1) did not itself bar the section 80G claim. The enhanced deduction claim under section 80-IA was not decided on merits and was remanded to the AO for verification of revised evidence and supporting material. On the transfer pricing issue, working capital adjustment was directed to be granted while re-examining receivables from associated enterprises. Computation of income, section 80M deduction, and interest under sections 244A and 234C were also restored for fresh consideration, and the challenge to penalty initiation was dismissed as premature. The appeal was partly allowed.
Deduction under section 80G was allowed for donations forming part of CSR expenditure because disallowance under Explanation 2 to section 37(1) did not itself bar the section 80G claim. The enhanced deduction claim under section 80-IA was not decided on merits and was remanded to the AO for verification of revised evidence and supporting material. On the transfer pricing issue, working capital adjustment was directed to be granted while re-examining receivables from associated enterprises. Computation of income, section 80M deduction, and interest under sections 244A and 234C were also restored for fresh consideration, and the challenge to penalty initiation was dismissed as premature. The appeal was partly allowed.
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