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 deposits - The tribunal rejected the notion that unexplained deposits prior to withdrawals undermined the explanation provided by the appellant. - Regarding the PCIT's assertion of the AO's mistake in not making the addition, the tribunal stated that an assessment order must be interpreted as is, without assumptions or postulations. If the AO had indeed erred, avenues for correction, such as rectification under Section 154 of the Act, were available but not utilized.
Revision u/s 263 - unexplained cash deposits - The tribunal rejected the notion that unexplained deposits prior to withdrawals undermined the explanation provided by the appellant. - Regarding the PCIT's assertion of the AO's mistake in not making the addition, the tribunal stated that an assessment order must be interpreted as is, without assumptions or postulations. If the AO had indeed erred, avenues for correction, such as rectification under Section 154 of the Act, were available but not utilized.
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