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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Consultancy charges paid to a sister concern were treated as genuine business expenditure because the agreements defined the work, supporting bills were on record, TDS and service tax had been deposited, and no fair market material showed the payment to be excessive; the related-party disallowance was deleted. Interest on vehicle loans was also allowed as business expenditure because the loans related to vehicles acquired in earlier years, part-year interest had been claimed previously, and the current-year increase reflected full-year interest on outstanding borrowings rather than fresh purchases; that disallowance was deleted.
Consultancy charges paid to a sister concern were treated as genuine business expenditure because the agreements defined the work, supporting bills were on record, TDS and service tax had been deposited, and no fair market material showed the payment to be excessive; the related-party disallowance was deleted. Interest on vehicle loans was also allowed as business expenditure because the loans related to vehicles acquired in earlier years, part-year interest had been claimed previously, and the current-year increase reflected full-year interest on outstanding borrowings rather than fresh purchases; that disallowance was deleted.
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