Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Assessment u/s 153A - The word “incriminating” has not been defined under the Act where it refers to those documents, materials, information which were collected during the search proceedings and simultaneously these documents had bearing on the total income of the assessee. The Tribunal, in the impugned order, has categorically observed that nothing was brought on record contrary to the findings of the CIT(A) and accordingly, no addition of the regular items which were disclosed by the assessee in the regular books of accounts can be made. - Consequently, the High court found that no substantial question of law arose from the Tribunal's order and dismissed the appeal.
Assessment u/s 153A - The word “incriminating” has not been defined under the Act where it refers to those documents, materials, information which were collected during the search proceedings and simultaneously these documents had bearing on the total income of the assessee. The Tribunal, in the impugned order, has categorically observed that nothing was brought on record contrary to the findings of the CIT(A) and accordingly, no addition of the regular items which were disclosed by the assessee in the regular books of accounts can be made. - Consequently, the High court found that no substantial question of law arose from the Tribunal's order and dismissed the appeal.
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