Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Cash deposits during demonetisation were accepted as explained where recorded sales, stock details, VAT returns and cash-in-hand records supported the books; the estimated gross profit addition failed because the books were rejected without specific defects, and the material showed stock-backed sales rather than suspicion. The Tribunal also held that M/s. Jain Bullion belonged to its proprietor, not the assessee, since the relevant bank accounts were operated by the proprietor and the concern had separately conducted business and filed returns. Separately, the notional annual letting value addition in search assessment was deleted because no incriminating material for that item was found during the search.
Cash deposits during demonetisation were accepted as explained where recorded sales, stock details, VAT returns and cash-in-hand records supported the books; the estimated gross profit addition failed because the books were rejected without specific defects, and the material showed stock-backed sales rather than suspicion. The Tribunal also held that M/s. Jain Bullion belonged to its proprietor, not the assessee, since the relevant bank accounts were operated by the proprietor and the concern had separately conducted business and filed returns. Separately, the notional annual letting value addition in search assessment was deleted because no incriminating material for that item was found during the search.
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