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...
Common area maintenance recoveries treated as business income supported allowance of related expenditure, and proportionate disallowance by reference to house property income was rejected where the assessee was contractually responsible only for common areas of the mall. Repairs and maintenance, legal and professional fees, employee remuneration, advertisement and sales promotion, and security charges were each held to be linked to mall management and CAM obligations rather than to rental income, subject only to limited factual restriction in respect of office and general expenses. The Tribunal also upheld the appellate authority's power to entertain and direct verification of an additional property tax deduction claim arising from the record.
Common area maintenance recoveries treated as business income supported allowance of related expenditure, and proportionate disallowance by reference to house property income was rejected where the assessee was contractually responsible only for common areas of the mall. Repairs and maintenance, legal and professional fees, employee remuneration, advertisement and sales promotion, and security charges were each held to be linked to mall management and CAM obligations rather than to rental income, subject only to limited factual restriction in respect of office and general expenses. The Tribunal also upheld the appellate authority's power to entertain and direct verification of an additional property tax deduction claim arising from the record.
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