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...
Revision u/s 263 - unexplained cash credit u/s 68 - the documents were very much available on ‘record’ when the ld PCIT examined this assessment folder. When all these details were already on record, it is reasonably expected from ld PCIT to look into those details (as already forming part of record) before arriving at any conclusion that whether the said loan was squared up during the year or not. - PCIT had totally proceeded on incorrect assumption of fact - AT
Revision u/s 263 - unexplained cash credit u/s 68 - the documents were very much available on ‘record’ when the ld PCIT examined this assessment folder. When all these details were already on record, it is reasonably expected from ld PCIT to look into those details (as already forming part of record) before arriving at any conclusion that whether the said loan was squared up during the year or not. - PCIT had totally proceeded on incorrect assumption of fact - AT
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