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 of contract receipts - bogus activity - Estimation of income - The AO had made an addition to the assessee's income, alleging discrepancies in the contract receipts and estimating the profit at 8%. However, upon careful consideration, the Tribunal found inconsistencies in the assessment. It questioned the basis for estimating profit at 8% when the commission ranged from 0.25% to 1%, and the discrepancy regarding the actual contract receipts. The Tribunal concluded that the addition lacked demonstrative evidence and was based on surmise and conjecture.
Addition of contract receipts - bogus activity - Estimation of income - The AO had made an addition to the assessee's income, alleging discrepancies in the contract receipts and estimating the profit at 8%. However, upon careful consideration, the Tribunal found inconsistencies in the assessment. It questioned the basis for estimating profit at 8% when the commission ranged from 0.25% to 1%, and the discrepancy regarding the actual contract receipts. The Tribunal concluded that the addition lacked demonstrative evidence and was based on surmise and conjecture.
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