Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Documentary evidence of allotment, continuity of shareholding and transfer deeds was treated as sufficient to prove that the shares sold were bonus shares held by the assessee. On that factual basis, the sale proceeds were not regarded as unexplained cash credit and were not taxed as income from other sources, despite discrepancies in the memorandum of understanding and consideration details. Because the quantum addition fell, the consequential penalty for furnishing inaccurate particulars also failed and was deleted.
Documentary evidence of allotment, continuity of shareholding and transfer deeds was treated as sufficient to prove that the shares sold were bonus shares held by the assessee. On that factual basis, the sale proceeds were not regarded as unexplained cash credit and were not taxed as income from other sources, despite discrepancies in the memorandum of understanding and consideration details. Because the quantum addition fell, the consequential penalty for furnishing inaccurate particulars also failed and was deleted.
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