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...
Addition u/s 68 - Disallowance of gift received from father and brother - the agricultural income disclosed by them cannot be disputed unless some facts emerged that they have not carried on agricultural activities or have suffered losses in the agricultural activities. Normally farmers do not rely on the banking channel for conducting their day to day activities and do accumulate cash balance - by the class of ration card possessed by the individuals one cannot determine such individuals to belong to people of poor means. - AT
Addition u/s 68 - Disallowance of gift received from father and brother - the agricultural income disclosed by them cannot be disputed unless some facts emerged that they have not carried on agricultural activities or have suffered losses in the agricultural activities. Normally farmers do not rely on the banking channel for conducting their day to day activities and do accumulate cash balance - by the class of ration card possessed by the individuals one cannot determine such individuals to belong to people of poor means. - AT
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