High Court Upholds 1% ALP for SBLC, Allows Excess R&D Expenditure Deduction.

The ITAT held that the TPO shall consider 1% rate as the arm's length price (ALP) for the international transaction involving issuance of Stand-by Letter of Credit (SBLC) to the associated enterprise (AE). The revenue expenditure claimed by the assessee, which exceeded the amount quantified by the DSIR, should be allowed as deduction u/s 37(1) after allowing the eligible portion u/s 35(2AB), as the AO erred in not examining whether the differential amount was for business purposes. .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X