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...
Additions for alleged unexplained chit subscriptions require year-specific corroborative evidence; an annual average derived from aggregate chit dealings and an uncorroborated statement cannot establish fresh investment in the relevant year. Loose sheets showing unpaid instalments and loan liabilities do not prove undisclosed income where bid amounts were repayable through later instalments. Likewise, unexplained interest expenditure requires evidence of actual payment in the relevant year; an estimate based on averaged aggregate figures is insufficient, particularly where interest was deducted upfront from borrowings. The ITAT sustained deletion of additions under sections 69 and 69C and dismissed the Revenue's appeals.
Additions for alleged unexplained chit subscriptions require year-specific corroborative evidence; an annual average derived from aggregate chit dealings and an uncorroborated statement cannot establish fresh investment in the relevant year. Loose sheets showing unpaid instalments and loan liabilities do not prove undisclosed income where bid amounts were repayable through later instalments. Likewise, unexplained interest expenditure requires evidence of actual payment in the relevant year; an estimate based on averaged aggregate figures is insufficient, particularly where interest was deducted upfront from borrowings. The ITAT sustained deletion of additions under sections 69 and 69C and dismissed the Revenue's appeals.
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