Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expenses.
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....The article discusses tribunal treatment of several business deduction issues: obsolete software licences were written off as no longer relevant to business use, so the write-off was accepted; section 80G deduction was allowed where donations were made by cheque or RTGS and receipts were supported despite technical defects; an ad hoc disallowance of trade payables was rejected because creditor details and payments were evidenced; bank guarantee charges were treated as revenue expenditure incurred for business purposes; royalty and technical service fees relating to international transactions were assessed through transfer pricing procedures; and a warranty provision was accepted as deductible when based on a scientific estimate and contractual obligation.....
TaxTMI