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...
Documentary evidence of purchase, holding and sale of listed shares, including contract notes, demat records and bank statements, was sufficient to discharge the initial onus of genuineness. General investigation-wing material on alleged penny stock accommodation entries could not sustain an addition under section 68 without independent inquiry or specific adverse evidence linking the assessee or broker to price manipulation. Denial of cross-examination of the persons whose statements were relied on further weakened the revenue case. As the section 68 addition failed, the consequential commission addition under section 69C also fell and was deleted.
Documentary evidence of purchase, holding and sale of listed shares, including contract notes, demat records and bank statements, was sufficient to discharge the initial onus of genuineness. General investigation-wing material on alleged penny stock accommodation entries could not sustain an addition under section 68 without independent inquiry or specific adverse evidence linking the assessee or broker to price manipulation. Denial of cross-examination of the persons whose statements were relied on further weakened the revenue case. As the section 68 addition failed, the consequential commission addition under section 69C also fell and was deleted.
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