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...
Actuarial provisions for employee benefits were treated as ascertained liabilities where the scheme existed and valuation was independently supported by actuarial assumptions, so the Bhavishya Kalyan Yojana provision was allowable under section 37(1) on the net claim revised by the assessee. The Tribunal also allowed the additional deduction for the Medicare Scheme actuarial loss disclosed in Other Comprehensive Income, because the facts were already on record and it related to the same employee benefit obligation. For salary and other expense provisions, disallowance for alleged non-deduction of tax at source was largely deleted where tax had been deducted under section 192 or no deduction was required; residual items were remanded for verification.
Actuarial provisions for employee benefits were treated as ascertained liabilities where the scheme existed and valuation was independently supported by actuarial assumptions, so the Bhavishya Kalyan Yojana provision was allowable under section 37(1) on the net claim revised by the assessee. The Tribunal also allowed the additional deduction for the Medicare Scheme actuarial loss disclosed in Other Comprehensive Income, because the facts were already on record and it related to the same employee benefit obligation. For salary and other expense provisions, disallowance for alleged non-deduction of tax at source was largely deleted where tax had been deducted under section 192 or no deduction was required; residual items were remanded for verification.
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