Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Revision u/s 263 - Genuineness of expenditure (Commission paid) - The ITAT found that the commission agreement was genuine, payments were made through banking channels, and tax was deducted at source, supporting the legitimacy of the transaction. Despite the substantial amount of commission paid, the ITAT emphasized that the genuineness of the transaction should be verified, which was found to be in order. The discrepancy in GST calculations and reported figures was deemed irrelevant by the ITAT. - The ITAT allowed the appeal of the assessee, quashing the order passed by the Ld. Pr. CIT under Section 263.
Revision u/s 263 - Genuineness of expenditure (Commission paid) - The ITAT found that the commission agreement was genuine, payments were made through banking channels, and tax was deducted at source, supporting the legitimacy of the transaction. Despite the substantial amount of commission paid, the ITAT emphasized that the genuineness of the transaction should be verified, which was found to be in order. The discrepancy in GST calculations and reported figures was deemed irrelevant by the ITAT. - The ITAT allowed the appeal of the assessee, quashing the order passed by the Ld. Pr. CIT under Section 263.
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