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...
Reassessment for unexplained investment in immovable property may be initiated where the income-tax return was only processed and material indicates that the investment, including an unexplained cash component, was disproportionate to disclosed income. Disclosure of the property purchase in a wealth-tax return does not by itself establish disclosure in the income-tax return of material facts concerning the source of funds or the transaction's true nature. Explanation 2(b) to section 147 may therefore apply. The assessing officer is not deemed to have considered information contained only in the wealth-tax return. Sanction under section 151 is satisfied where the approving authority records satisfaction on the assessing officer's recorded reasons.
Reassessment for unexplained investment in immovable property may be initiated where the income-tax return was only processed and material indicates that the investment, including an unexplained cash component, was disproportionate to disclosed income. Disclosure of the property purchase in a wealth-tax return does not by itself establish disclosure in the income-tax return of material facts concerning the source of funds or the transaction's true nature. Explanation 2(b) to section 147 may therefore apply. The assessing officer is not deemed to have considered information contained only in the wealth-tax return. Sanction under section 151 is satisfied where the approving authority records satisfaction on the assessing officer's recorded reasons.
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