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...
Reassessment jurisdiction was upheld because the earlier scrutiny proceedings had already been dropped pursuant to CBDT directions, and the assessee's participation without objection attracted deemed service of notice under section 292BB. The addition for unexplained money was deleted, as earlier cash withdrawals shortly before the redeposit in the same bank account were treated as an available source and the contrary inference was found conjectural. The claim for indexed cost of improvement on sale of house property was remanded for fresh verification, with direction to allow the construction cost if proved. Penalties were adjusted consequentially: the penalty linked to the deleted addition was vacated, the penalty linked to the sustained addition was upheld, and the penalty on the remanded issue was set aside subject to fresh proceedings.
Reassessment jurisdiction was upheld because the earlier scrutiny proceedings had already been dropped pursuant to CBDT directions, and the assessee's participation without objection attracted deemed service of notice under section 292BB. The addition for unexplained money was deleted, as earlier cash withdrawals shortly before the redeposit in the same bank account were treated as an available source and the contrary inference was found conjectural. The claim for indexed cost of improvement on sale of house property was remanded for fresh verification, with direction to allow the construction cost if proved. Penalties were adjusted consequentially: the penalty linked to the deleted addition was vacated, the penalty linked to the sustained addition was upheld, and the penalty on the remanded issue was set aside subject to fresh proceedings.
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