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...
Assessee's explanation for the alleged shortfall in wastage was supported by job-work records, invoices and confirmations, and the Tribunal found no factual infirmity; the rejection of books and estimated gross profit addition were therefore deleted. In reassessment, additions for contract-payment TDS default and delayed provident fund contribution could not survive once the recorded reason for reopening itself failed in appeal, because jurisdiction to sustain unrelated additions depends on survival of the original reopening ground. A donation deduction disallowance was not decided on merits, as adverse material was not furnished and cross-examination was denied; the matter was restored for fresh adjudication after due hearing.
Assessee's explanation for the alleged shortfall in wastage was supported by job-work records, invoices and confirmations, and the Tribunal found no factual infirmity; the rejection of books and estimated gross profit addition were therefore deleted. In reassessment, additions for contract-payment TDS default and delayed provident fund contribution could not survive once the recorded reason for reopening itself failed in appeal, because jurisdiction to sustain unrelated additions depends on survival of the original reopening ground. A donation deduction disallowance was not decided on merits, as adverse material was not furnished and cross-examination was denied; the matter was restored for fresh adjudication after due hearing.
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