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...
Estimation of income - bogus purchases - case of bogus bills arranged from the entities and diamonds purchased from somewhere else at a lower cost - The ITAT noted the absence of crucial documentation, such as delivery challans, to substantiate the purchases. Consequently, the disallowance of purchases was upheld. - Considering the appellant's argument for a lower percentage of disallowance based on the profit margin accepted in other assessment years, the Tribunal decided to restrict the disallowance to 5% of the disputed purchases, consistent with previous decisions in the appellant's case.
Estimation of income - bogus purchases - case of bogus bills arranged from the entities and diamonds purchased from somewhere else at a lower cost - The ITAT noted the absence of crucial documentation, such as delivery challans, to substantiate the purchases. Consequently, the disallowance of purchases was upheld. - Considering the appellant's argument for a lower percentage of disallowance based on the profit margin accepted in other assessment years, the Tribunal decided to restrict the disallowance to 5% of the disputed purchases, consistent with previous decisions in the appellant's case.
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