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...
ITAT held that cash deposits in a small trader's bank account, including interest, could not again be assessed as unexplained income where they arose from retail trading receipts and profit had already been offered on those receipts. Accepting that the assessee dealt in agricultural produce and had disclosed presumptive profit at 5% on business turnover, the Tribunal applied the principle that once bank deposits are treated as turnover and taxed through estimated profit, the entire deposits cannot be added again. The addition made by the lower authority was deleted.
ITAT held that cash deposits in a small trader's bank account, including interest, could not again be assessed as unexplained income where they arose from retail trading receipts and profit had already been offered on those receipts. Accepting that the assessee dealt in agricultural produce and had disclosed presumptive profit at 5% on business turnover, the Tribunal applied the principle that once bank deposits are treated as turnover and taxed through estimated profit, the entire deposits cannot be added again. The addition made by the lower authority was deleted.
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