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...
Mechanical approval for search assessments under section 153D was held invalid where the sanction was consolidated, year-neutral and showed no application of mind, so the assessments were quashed as void ab initio. Completed years could not be reopened under section 153A in the absence of incriminating material. Where the Revenue relied on documents from a third party's search, the mandatory section 153C route had to be followed, and assessments framed without it were without jurisdiction. The Tribunal also deleted additions based on estimated project income, loose sheets without corroboration, assumed project receipts, and cash deposits supported by agricultural records and sale documents.
Mechanical approval for search assessments under section 153D was held invalid where the sanction was consolidated, year-neutral and showed no application of mind, so the assessments were quashed as void ab initio. Completed years could not be reopened under section 153A in the absence of incriminating material. Where the Revenue relied on documents from a third party's search, the mandatory section 153C route had to be followed, and assessments framed without it were without jurisdiction. The Tribunal also deleted additions based on estimated project income, loose sheets without corroboration, assumed project receipts, and cash deposits supported by agricultural records and sale documents.
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