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...
Disallowance under section 14A cannot exceed the exempt income earned in the relevant year, so a higher Rule 8D disallowance was not sustainable where the assessee had already made a suo motu disallowance. The Tribunal upheld restriction of the disallowance to the amount already offered by the assessee. On CSR-related donations, it held that Explanation 2 to section 37(1) only denies CSR expenditure as business deduction and does not bar a separate deduction under section 80G if the statutory conditions are met. Approved donee status and banking-channel payments supported the claim, so the deduction was upheld.
Disallowance under section 14A cannot exceed the exempt income earned in the relevant year, so a higher Rule 8D disallowance was not sustainable where the assessee had already made a suo motu disallowance. The Tribunal upheld restriction of the disallowance to the amount already offered by the assessee. On CSR-related donations, it held that Explanation 2 to section 37(1) only denies CSR expenditure as business deduction and does not bar a separate deduction under section 80G if the statutory conditions are met. Approved donee status and banking-channel payments supported the claim, so the deduction was upheld.
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