Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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A revised return that only claimed TDS credit did not require a fresh scrutiny notice where a notice under section 143(2) had already been issued on the original return and no prejudice was shown from the absence of a second notice. For unexplained cash deposits, amounts already taxed in an earlier year could not be assessed again as the same income, and further relief was allowed having regard to the assessee's age, deposit pattern and past income history; only the unexplained balance remained taxable under section 69A. The higher rate under section 115BBE was held prospective, so the surviving addition was to be taxed at the pre-amendment rate.
A revised return that only claimed TDS credit did not require a fresh scrutiny notice where a notice under section 143(2) had already been issued on the original return and no prejudice was shown from the absence of a second notice. For unexplained cash deposits, amounts already taxed in an earlier year could not be assessed again as the same income, and further relief was allowed having regard to the assessee's age, deposit pattern and past income history; only the unexplained balance remained taxable under section 69A. The higher rate under section 115BBE was held prospective, so the surviving addition was to be taxed at the pre-amendment rate.
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