Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Unexplained cash deposits were sustained as additions because the assessee failed to discharge the onus of explaining their source and nature. The record showed continuing inconsistencies between the cash deposits, declared turnover, GST returns and accounting entries, and no reliable reconciliation was produced to link the deposits to alleged client reimbursements and booking advances in the travel business. In the absence of a verifiable explanation, the Tribunal found invocation of unexplained-income treatment and the consequential higher-tax regime justified, and the addition was upheld.
Unexplained cash deposits were sustained as additions because the assessee failed to discharge the onus of explaining their source and nature. The record showed continuing inconsistencies between the cash deposits, declared turnover, GST returns and accounting entries, and no reliable reconciliation was produced to link the deposits to alleged client reimbursements and booking advances in the travel business. In the absence of a verifiable explanation, the Tribunal found invocation of unexplained-income treatment and the consequential higher-tax regime justified, and the addition was upheld.
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