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...
Unexplained investment in immovable property under section 69 was held explained where the assessee produced the sale deed, the father's bank statement, and proof of direct payment to the seller through banking channels. The Tribunal held that this discharged the primary onus; the burden then shifted to the Revenue to bring adverse material, which it did not. Mere suspicion about antecedent credits in the father's account was insufficient, and the absence of a formal gift deed did not by itself make the investment unexplained in a family transaction. The addition was deleted in full.
Unexplained investment in immovable property under section 69 was held explained where the assessee produced the sale deed, the father's bank statement, and proof of direct payment to the seller through banking channels. The Tribunal held that this discharged the primary onus; the burden then shifted to the Revenue to bring adverse material, which it did not. Mere suspicion about antecedent credits in the father's account was insufficient, and the absence of a formal gift deed did not by itself make the investment unexplained in a family transaction. The addition was deleted in full.
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