https://www.taxtmi.com/caselaws?id=328923 Transfer pricing adjustment on management charges was restored for de novo examination because material evidence had not been tested at the assessment stage. Disallowance under section 14A read with Rule 8D could not include mutual fund investments that did not generate exempt income, so the adjustment was reduced. Foreign receipts were taxable on the income amount in India, and foreign tax deduction did not reduce taxable income, though relief under section 90 remained available. Software licence payments made for use were revenue expenditure, and legal expenses connected with sale structuring were also allowable as business revenue outgoings. The Revenue's challenge to deletion of additions for negative contract margin and prior period expenses was rejected. en-us Wed, 06 Apr 2016 00:00:00 +0530 Sat, 18 Jun 2016 08:39:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=328923 Transfer pricing adjustment on management charges was restored for de novo examination because material evidence had not been tested at the assessment stage. Disallowance under section 14A read with Rule 8D could not include mutual fund investments that did not generate exempt income, so the adjustment was reduced. Foreign receipts were taxable on the income amount in India, and foreign tax deduction did not reduce taxable income, though relief under section 90 remained available. Software licence payments made for use were revenue expenditure, and legal expenses connected with sale structuring were also allowable as business revenue outgoings. The Revenue's challenge to deletion of additions for negative contract margin and prior period expenses was rejected. Case-Laws Income Tax Wed, 06 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=328923