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...
Adopting the commission income at 0.5% - Unexplained bank deposits - assessee could not rebut the fact that the assessee himself has stated of having received commission in cash @ 0.5% out of which 0.3% was paid as bank charges. We find that the CIT(Appeal) on the basis of this statement has adopted the commission income but he has allowed the expenses on the actual basis - statement cannot be used in part. It is to be read as a whole. Therefore, considering the statement of the assessee we hereby direct the Assessing Officer to adopt 0.20% as the net commission income of the assessee. - AT
Adopting the commission income at 0.5% - Unexplained bank deposits - assessee could not rebut the fact that the assessee himself has stated of having received commission in cash @ 0.5% out of which 0.3% was paid as bank charges. We find that the CIT(Appeal) on the basis of this statement has adopted the commission income but he has allowed the expenses on the actual basis - statement cannot be used in part. It is to be read as a whole. Therefore, considering the statement of the assessee we hereby direct the Assessing Officer to adopt 0.20% as the net commission income of the assessee. - AT
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