Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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An ITAT deleted an addition under section 69C for alleged on-money payment because the assessment rested only on an investigation report, a seized excel sheet naming another person, and a general builder's employee statement. The assessee's banking-channel payment evidence was not rebutted, and no independent corroboration of cash payment was brought on record. The third-party statement was untested by cross-examination and could not, by itself, sustain the addition. The appeal was partly allowed.
An ITAT deleted an addition under section 69C for alleged on-money payment because the assessment rested only on an investigation report, a seized excel sheet naming another person, and a general builder's employee statement. The assessee's banking-channel payment evidence was not rebutted, and no independent corroboration of cash payment was brought on record. The third-party statement was untested by cross-examination and could not, by itself, sustain the addition. The appeal was partly allowed.
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