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...
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The Tribunal held that the interest on overdue receivables from associated enterprises could not be benchmarked at LIBOR plus 450 basis points because no justification was given for that rate, and directed recomputation at LIBOR plus 200 basis points. The ESOP-cost dispute was treated as infructuous since no transfer pricing adjustment survived in the ITeS segment. On CSR donations, it held that contributions made to trusts eligible under section 80G were not barred merely because they formed part of CSR expenditure, and directed allowance of the deduction where the assessee had not claimed section 37 relief. Interest under sections 234A and 234C was left to be recomputed in accordance with law.
The Tribunal held that the interest on overdue receivables from associated enterprises could not be benchmarked at LIBOR plus 450 basis points because no justification was given for that rate, and directed recomputation at LIBOR plus 200 basis points. The ESOP-cost dispute was treated as infructuous since no transfer pricing adjustment survived in the ITeS segment. On CSR donations, it held that contributions made to trusts eligible under section 80G were not barred merely because they formed part of CSR expenditure, and directed allowance of the deduction where the assessee had not claimed section 37 relief. Interest under sections 234A and 234C was left to be recomputed in accordance with law.
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