Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
A CBDT-prescribed format defect in notice under section 143(2) was held to be only a technical irregularity and not, by itself, a ground to invalidate the assessment. The rejection of books under section 145(3) was found unjustified because specific reasons for such rejection were not properly established, although the cash-book discrepancies could still be examined for a separate addition under section 69A. On the cash-deposit issue, the matter was remanded for de novo assessment so the assessee could produce supporting evidence and the Assessing Officer could decide the source of deposits afresh after affording effective hearing.
A CBDT-prescribed format defect in notice under section 143(2) was held to be only a technical irregularity and not, by itself, a ground to invalidate the assessment. The rejection of books under section 145(3) was found unjustified because specific reasons for such rejection were not properly established, although the cash-book discrepancies could still be examined for a separate addition under section 69A. On the cash-deposit issue, the matter was remanded for de novo assessment so the assessee could produce supporting evidence and the Assessing Officer could decide the source of deposits afresh after affording effective hearing.
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