Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Receipts from standard software licences or subscriptions, together with incidental support services, were held not to constitute fees for technical services because the offerings were standardised and automated, with only a limited, non-transferable right of access or use and no transfer of source code, proprietary rights, or commercial exploitation rights. The related support was treated as ancillary to the software supply, not as separate managerial, technical, or consultancy services. On that basis, the software-related addition was deleted for A.Y. 2020-21, and the same reasoning was applied to A.Y. 2021-22. The refund adjustment issue was not decided on merits and was remanded for limited verification and consequential relief, if due.
Receipts from standard software licences or subscriptions, together with incidental support services, were held not to constitute fees for technical services because the offerings were standardised and automated, with only a limited, non-transferable right of access or use and no transfer of source code, proprietary rights, or commercial exploitation rights. The related support was treated as ancillary to the software supply, not as separate managerial, technical, or consultancy services. On that basis, the software-related addition was deleted for A.Y. 2020-21, and the same reasoning was applied to A.Y. 2021-22. The refund adjustment issue was not decided on merits and was remanded for limited verification and consequential relief, if due.
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