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...
Unaccounted business receipts from a garment-export business were treated as business turnover, so only the embedded gross profit, rather than the full receipts, was taxable. Based on the audited profitability trend, the reported ITAT decision restricted the gross-profit estimate to 1% of aggregated unaccounted sales, including token-note receipts. Alleged cash-salary additions were deleted because the recipient's statements were contradictory, cross-examination denied cash or cheque salary, and no independent support existed. Additions for cash, a gold coin and foreign currency were also deleted because recorded balances, the gift explanation and client confirmation of currency ownership remained unrebutted.
Unaccounted business receipts from a garment-export business were treated as business turnover, so only the embedded gross profit, rather than the full receipts, was taxable. Based on the audited profitability trend, the reported ITAT decision restricted the gross-profit estimate to 1% of aggregated unaccounted sales, including token-note receipts. Alleged cash-salary additions were deleted because the recipient's statements were contradictory, cross-examination denied cash or cheque salary, and no independent support existed. Additions for cash, a gold coin and foreign currency were also deleted because recorded balances, the gift explanation and client confirmation of currency ownership remained unrebutted.
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