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...
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Rectification u/s 254 - addition u/s. 153A - onus was upon the assessee to prove this in view of the materials found during search and the presumptions arising out of provisions of section 132(4A). Instead the learned CIT-A has put the onus on assessing officer to prove that the impugned sum was paid by other means by the assessee. In our considered opinion, the action of the learned CIT-A is clearly contrary to the mandate of provisions of section 132(4A) and the incriminating documents found - The assessee in its miscellaneous application is agitating the same points which have already been dealt with in the ITAT order. - Application dismissed.
Rectification u/s 254 - addition u/s. 153A - onus was upon the assessee to prove this in view of the materials found during search and the presumptions arising out of provisions of section 132(4A). Instead the learned CIT-A has put the onus on assessing officer to prove that the impugned sum was paid by other means by the assessee. In our considered opinion, the action of the learned CIT-A is clearly contrary to the mandate of provisions of section 132(4A) and the incriminating documents found - The assessee in its miscellaneous application is agitating the same points which have already been dealt with in the ITAT order. - Application dismissed.
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