Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Reassessment for a claimed deduction for political contributions under section 80GGC may examine whether the payment was a genuine donation or an accommodation entry. The Tribunal's reported analysis states that banking-channel payments and donation receipts do not prevent scrutiny of surrounding circumstances. Investigation material, statements recorded under section 132(4), bank-trail analysis and evidence of fund layering by the recipient political party were treated as a chain of circumstances under the test of human probabilities, indicating an accommodation entry. The article reports that the reassessment notice was validly issued, the deduction was disallowed, and the appeal was dismissed.
Reassessment for a claimed deduction for political contributions under section 80GGC may examine whether the payment was a genuine donation or an accommodation entry. The Tribunal's reported analysis states that banking-channel payments and donation receipts do not prevent scrutiny of surrounding circumstances. Investigation material, statements recorded under section 132(4), bank-trail analysis and evidence of fund layering by the recipient political party were treated as a chain of circumstances under the test of human probabilities, indicating an accommodation entry. The article reports that the reassessment notice was validly issued, the deduction was disallowed, and the appeal was dismissed.
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