The ITAT held that the TPO shall consider 1% rate as the arm's ...

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

January 22, 2025

Case Laws Income Tax AT

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.

View Source

← Previous Next →

The ITAT held that the TPO shall consider 1% rate as the arm's ...

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

January 22, 2025

Case Laws Income Tax AT

You may also like:

Product Development Expenditure disallowed - there is no distinction as to whether the expenditure incurred is capital or revenue, because while the provisions of...

The assessee claimed weighted deduction u/s 35(1)(ii) for donation made to M/s Shri Arvindo Institute of Applied Scientific Research Trust at the end of the year. The...

Disallowances under section 30(1) - expenditure incurred on repair and renovation of renting premises allowed - HC

Payment made for surrender of tenancy rights - deduction allowed u/s 37(1) - AT

Deduction u/s 36(1)(iii) - double deduction for deduction of interest - once these amounts are allowed as deduction in the year of incurring the expenditure, the same...

Deduction u/s 35(2AB) - Expenditure which was not eligible for weighted deduction u/s 35(2AB) - scientific research and development expenditure - such R&D expenditure...

Nature of expenditure - Expenditure incurred by the assessee towards repairs and renovation of the premises to house the branch - if the expenditure incurred by the...

Appellant eligible for weighted deduction u/s 35(2AB) for entire R&D expenditure incurred in India. Revenue R&D expenditure incurred outside India allowed in assessment....

Revision u/s 263 - Deduction u/s 36(1)(viii) - Insofar as, the second issue of excess allowances of deduction u/s.36 (1)(vii), the assessment order passed by the AO is...

Software development expenditure which was application software was revenue in nature - deduction allowed u/s 37.

Deduction u/s 37 - Guarantee commission paid to State Government – allowed as revenue expenditure - HC

TP adjustment of interest - CIT(A) confirmed upward adjustment towards interest by adopting rupee loan rate instead of LIBOR linked rate in respect of foreign currency...

The assessee claimed deduction for compensation paid to farmers for acquiring mining rights, which was an allowable expenditure. The Assessing Officer allowed the...

Weighted deductions claimed u/s 35(2AB) - The petitioner challenged the restriction of the eligibility period for weighted deductions on R&D expenditure, contending it...

The assessee claimed excess deduction u/s 36(1)(viia) for provision for bad and doubtful debts, leading to escapement of income. The Assessing Officer rightly formed the...

Quick Updates: