Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Cancellation of a supplier's GST registration, by itself, does not justify treating purchases as non-genuine where the supplier had died, the proprietary business had ceased on that account, and the purchase invoices and transport documents predated the death. The assessee's explanation for the supplier's non-response was accepted, and the Revenue had not identified any discrepancy in the purchases or disputed the corresponding sales. On those facts, disallowance of the purchases and the resulting addition were unjustified and were deleted.
Cancellation of a supplier's GST registration, by itself, does not justify treating purchases as non-genuine where the supplier had died, the proprietary business had ceased on that account, and the purchase invoices and transport documents predated the death. The assessee's explanation for the supplier's non-response was accepted, and the Revenue had not identified any discrepancy in the purchases or disputed the corresponding sales. On those facts, disallowance of the purchases and the resulting addition were unjustified and were deleted.
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