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...
Penny-stock share sale proceeds cannot be treated as unexplained money merely on suspicion of accommodation entries where purchases and sales occurred through banking channels, demat accounts and the stock exchange. Investigation findings about broker manipulation require material linking the taxpayer to bogus purchases, cash exchanges, price rigging or an entry arrangement; absent such evidence, documentary transaction records prevail and the addition is unsustainable. Exempt long-term capital gains nevertheless require disclosure through a return, and failure to file a return for the relevant year can justify reassessment proceedings.
Penny-stock share sale proceeds cannot be treated as unexplained money merely on suspicion of accommodation entries where purchases and sales occurred through banking channels, demat accounts and the stock exchange. Investigation findings about broker manipulation require material linking the taxpayer to bogus purchases, cash exchanges, price rigging or an entry arrangement; absent such evidence, documentary transaction records prevail and the addition is unsustainable. Exempt long-term capital gains nevertheless require disclosure through a return, and failure to file a return for the relevant year can justify reassessment proceedings.
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