Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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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