https://www.taxtmi.com/caselaws?id=414001 Income from training activity closely linked to the software business was treated as eligible for section 10A, and included in export and total turnover. Interest from temporary deployment of surplus funds was also regarded as connected with the export undertaking, subject to verification of supporting evidence by the Assessing Officer. Transfer pricing adjustments on delayed receivables, customization fee, and guarantee commission on loans to associated enterprises were not sustained because the factual record did not show any arm's length shortfall or independent benefit to the associated enterprises. Interest under section 234D was held chargeable, so the assessee succeeded on the main section 10A and transfer pricing issues, but the Revenue prevailed on section 234D. en-us Tue, 12 Oct 2021 00:00:00 +0530 Mon, 25 Oct 2021 11:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=414001 Income from training activity closely linked to the software business was treated as eligible for section 10A, and included in export and total turnover. Interest from temporary deployment of surplus funds was also regarded as connected with the export undertaking, subject to verification of supporting evidence by the Assessing Officer. Transfer pricing adjustments on delayed receivables, customization fee, and guarantee commission on loans to associated enterprises were not sustained because the factual record did not show any arm's length shortfall or independent benefit to the associated enterprises. Interest under section 234D was held chargeable, so the assessee succeeded on the main section 10A and transfer pricing issues, but the Revenue prevailed on section 234D. Case-Laws Income Tax Tue, 12 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=414001