https://www.taxtmi.com/caselaws?id=279772 The Tribunal partly allowed the assessee's appeal and dismissed the revenue's appeal. The disallowance under Section 40(a)(ia) regarding payments for software licenses treated as royalty was deleted due to the bona fide belief before a relevant court decision. Transfer pricing adjustments were set aside for proper verification of cost allocation. The treatment of foreign exchange gain/loss as operating revenue/cost was upheld based on consistent tribunal views. The Tribunal emphasized actual cost allocation, non-retrospective TDS obligations, and consistent treatment of foreign exchange fluctuations. en-us Fri, 15 Sep 2017 00:00:00 +0530 Thu, 04 Aug 2022 18:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=279772 The Tribunal partly allowed the assessee's appeal and dismissed the revenue's appeal. The disallowance under Section 40(a)(ia) regarding payments for software licenses treated as royalty was deleted due to the bona fide belief before a relevant court decision. Transfer pricing adjustments were set aside for proper verification of cost allocation. The treatment of foreign exchange gain/loss as operating revenue/cost was upheld based on consistent tribunal views. The Tribunal emphasized actual cost allocation, non-retrospective TDS obligations, and consistent treatment of foreign exchange fluctuations. Case-Laws Income Tax Fri, 15 Sep 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=279772