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...
Protective addition on account of unexplained credit entries appearing in the bank account - assessee company is a conduit - addition on account of unaccounted commission @ 0.25 % of total unexplained credit entries - The CIT(A) had deleted these additions, finding that the assessee acted as a conduit for accommodation entries, with identified beneficiaries, thus no further addition was warranted in the assessee's hands. The ITAT upheld the CIT(A)'s decision, noting that since the assessee operated as a conduit managed by certain individuals for providing accommodation entries, no addition for commission income was justified.
Protective addition on account of unexplained credit entries appearing in the bank account - assessee company is a conduit - addition on account of unaccounted commission @ 0.25 % of total unexplained credit entries - The CIT(A) had deleted these additions, finding that the assessee acted as a conduit for accommodation entries, with identified beneficiaries, thus no further addition was warranted in the assessee's hands. The ITAT upheld the CIT(A)'s decision, noting that since the assessee operated as a conduit managed by certain individuals for providing accommodation entries, no addition for commission income was justified.
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