Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Material evidence on unsecured loans must be considered before sustaining an addition for unexplained cash credits. The High Court noted that the Tribunal did not discuss the assessee's evidence on the lenders' source of funds, made no finding on the explanation of the source of source, and merely repeated the Assessing Officer's conclusions. It also rejected the assessee's cited precedents without examining their factual applicability. The article records that the Tribunal's order on the cash-credit addition was set aside and remanded for fresh consideration after reviewing all material and hearing the parties, with merits left open.
Material evidence on unsecured loans must be considered before sustaining an addition for unexplained cash credits. The High Court noted that the Tribunal did not discuss the assessee's evidence on the lenders' source of funds, made no finding on the explanation of the source of source, and merely repeated the Assessing Officer's conclusions. It also rejected the assessee's cited precedents without examining their factual applicability. The article records that the Tribunal's order on the cash-credit addition was set aside and remanded for fresh consideration after reviewing all material and hearing the parties, with merits left open.
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