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...
Estimated stock additions based on sample weighment and incomplete books were deleted where no scientific basis for the stock working was shown and the assessee's reconciliation went unrebutted. WhatsApp chats and section 132(4) statements supported some suppression of production, but extrapolation to the whole year was rejected; only 10% profit on the limited-period difference was sustained. Long-outstanding sundry creditors did not attract section 41(1) absent evidence of remission or benefit. For completed years, additions under section 153A required incriminating search material, so extrapolation alone could not support the earlier years. Unsecured loans were accepted where identity, creditworthiness, genuineness, banking trail and repayment were proved. A third-party Tally ledger, without linkage to the assessee's own records, could not sustain an unexplained investment addition.
Estimated stock additions based on sample weighment and incomplete books were deleted where no scientific basis for the stock working was shown and the assessee's reconciliation went unrebutted. WhatsApp chats and section 132(4) statements supported some suppression of production, but extrapolation to the whole year was rejected; only 10% profit on the limited-period difference was sustained. Long-outstanding sundry creditors did not attract section 41(1) absent evidence of remission or benefit. For completed years, additions under section 153A required incriminating search material, so extrapolation alone could not support the earlier years. Unsecured loans were accepted where identity, creditworthiness, genuineness, banking trail and repayment were proved. A third-party Tally ledger, without linkage to the assessee's own records, could not sustain an unexplained investment addition.
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