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 dealt with three business expenditure claims. It deleted disallowance of input tax credit reversal because the amount was shown to form part of total project cost and was apportioned between cost of sales and closing work-in-progress, so the factual basis for rejection failed. It remanded the claim for advances written off as trading loss because the assessee had to first establish business purpose and irrecoverability, and was allowed to produce further evidence. It sustained disallowance of social activity and charitable expenditure, holding that charitable outlays and an unexplained training fee had no demonstrated nexus with the real estate business.
The Tribunal dealt with three business expenditure claims. It deleted disallowance of input tax credit reversal because the amount was shown to form part of total project cost and was apportioned between cost of sales and closing work-in-progress, so the factual basis for rejection failed. It remanded the claim for advances written off as trading loss because the assessee had to first establish business purpose and irrecoverability, and was allowed to produce further evidence. It sustained disallowance of social activity and charitable expenditure, holding that charitable outlays and an unexplained training fee had no demonstrated nexus with the real estate business.
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