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 and 69C - It is neither the AO’s case that the loan creditors are not income-tax assessee’s nor has he alleged that the documents and evidences furnished by the appellant in support of loan transactions were false or suffered from defects or do not tally with the Department’s records. - Aggregate additions being principal loan amount received by the appellant from the fifteen bodies corporate did not constitute its income chargeable u/s 68 of the Act. - AT
Addition u/s 68 and 69C - It is neither the AO’s case that the loan creditors are not income-tax assessee’s nor has he alleged that the documents and evidences furnished by the appellant in support of loan transactions were false or suffered from defects or do not tally with the Department’s records. - Aggregate additions being principal loan amount received by the appellant from the fifteen bodies corporate did not constitute its income chargeable u/s 68 of the Act. - AT
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