Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Sale advances supported by a seized agreement, receipt and subsequent conveyance were treated as explained sale consideration rather than unexplained money under section 69A. The notes state that any suppressed consideration would instead be considered under capital gains in the relevant assessment year, and the section 69A additions were vacated. For section 153C, the relevant date for exclusion is stated to be the search initiation date, not later receipt of seized material; the deeming provision is confined to identifying abated assessment years, so the jurisdictional challenge failed. The mechanical-approval challenge under section 153D also failed for lack of cogent supporting material. The consolidated satisfaction-note issue remained open.
Sale advances supported by a seized agreement, receipt and subsequent conveyance were treated as explained sale consideration rather than unexplained money under section 69A. The notes state that any suppressed consideration would instead be considered under capital gains in the relevant assessment year, and the section 69A additions were vacated. For section 153C, the relevant date for exclusion is stated to be the search initiation date, not later receipt of seized material; the deeming provision is confined to identifying abated assessment years, so the jurisdictional challenge failed. The mechanical-approval challenge under section 153D also failed for lack of cogent supporting material. The consolidated satisfaction-note issue remained open.
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