Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Bogus purchase bills obtained as accommodation entries warranted addition only to the income component embedded in unverifiable purchases, and the Tribunal was justified in following earlier coordinate Bench decisions on identical facts. The assessee had no actual material purchases, but the addition was restricted to 6% of the impugned purchases in line with prior High Court and Tribunal rulings. The Revenue's challenge to that estimation failed, and the appeal was dismissed.
Bogus purchase bills obtained as accommodation entries warranted addition only to the income component embedded in unverifiable purchases, and the Tribunal was justified in following earlier coordinate Bench decisions on identical facts. The assessee had no actual material purchases, but the addition was restricted to 6% of the impugned purchases in line with prior High Court and Tribunal rulings. The Revenue's challenge to that estimation failed, and the appeal was dismissed.
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