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...
HC held that reassessment based on seized third-party material requires prima facie material with a live link to the assessee and the alleged escapement of income. A loose paper seized from a broker, which did not name the assessee or contain identifiable particulars, could not by itself support an on-money allegation, especially when the rate was sought to be applied years later through a sale deed record. The broker's statement also did not connect the assessee with the document. The Court said the Revenue must assess the seized material with attendant circumstances and record prima facie relevance; vague, irrelevant and non-specific material could not justify reopening. The reassessment notice was quashed.
HC held that reassessment based on seized third-party material requires prima facie material with a live link to the assessee and the alleged escapement of income. A loose paper seized from a broker, which did not name the assessee or contain identifiable particulars, could not by itself support an on-money allegation, especially when the rate was sought to be applied years later through a sale deed record. The broker's statement also did not connect the assessee with the document. The Court said the Revenue must assess the seized material with attendant circumstances and record prima facie relevance; vague, irrelevant and non-specific material could not justify reopening. The reassessment notice was quashed.
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