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...
Documentary evidence of a newly inducted partner's capital contribution through banking instruments can discharge the assessee's onus for cash-credit purposes. Where pay-in slips, the partner's capital account and the balance sheet establish that the credit represents partner capital, the absence of a partner confirmation alone does not establish that the explanation is false. Relying on the principle in Pankaj Dyestuff Industries, the High Court treated the unexplained-cash-credit addition as perverse and deleted it, allowing the tax appeal.
Documentary evidence of a newly inducted partner's capital contribution through banking instruments can discharge the assessee's onus for cash-credit purposes. Where pay-in slips, the partner's capital account and the balance sheet establish that the credit represents partner capital, the absence of a partner confirmation alone does not establish that the explanation is false. Relying on the principle in Pankaj Dyestuff Industries, the High Court treated the unexplained-cash-credit addition as perverse and deleted it, allowing the tax appeal.
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