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 - accommodation entry - issue of shares for consideration other than 'cash' - "Adjustment by way of book entry" can only be in the case where there is already some liability/asset/entry in books of account's which is to be adjusted. However, in the instant case that was not the case. There was no entry subsisting in the books of account's which was adjusted.This was a fresh issue of equity shares for consideration other than cash, and was not issued against any of liability in the books of accounts. - additions confirmed - AT
Addition u/s 68 - accommodation entry - issue of shares for consideration other than 'cash' - "Adjustment by way of book entry" can only be in the case where there is already some liability/asset/entry in books of account's which is to be adjusted. However, in the instant case that was not the case. There was no entry subsisting in the books of account's which was adjusted.This was a fresh issue of equity shares for consideration other than cash, and was not issued against any of liability in the books of accounts. - additions confirmed - AT
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