Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Section 40(a)(ia) disallowance applies only to expenditure actually claimed as a deduction in computing business income; where TDS-defaulted amounts remained capitalised in work-in-progress and were not charged to the profit and loss account, no current-year disallowance was warranted. Even under the percentage completion method, the decisive question was whether the expense had entered the year's computation, and the balance had to be adjusted in work-in-progress to avoid later deduction without compliance. The audit report could not override the actual accounting treatment. The Tribunal therefore upheld the CIT(A)'s limited verification approach and dismissed the Revenue's appeal.
Section 40(a)(ia) disallowance applies only to expenditure actually claimed as a deduction in computing business income; where TDS-defaulted amounts remained capitalised in work-in-progress and were not charged to the profit and loss account, no current-year disallowance was warranted. Even under the percentage completion method, the decisive question was whether the expense had entered the year's computation, and the balance had to be adjusted in work-in-progress to avoid later deduction without compliance. The audit report could not override the actual accounting treatment. The Tribunal therefore upheld the CIT(A)'s limited verification approach and dismissed the Revenue's appeal.
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