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 u/s 68 - bogus share application/allotment money - The Court noted the factual examination done by the Commissioner of Income Tax (Appeals) regarding the share capital of the companies involved. It found that the share capital raised by one of the companies in the assessment year 2009-10 had already been added back in the hands of the party, indicating its genuineness. The Court upheld the action of the Commissioner of Income Tax (Appeals) and ITAT in deleting the additions.
Addition u/s 68 - bogus share application/allotment money - The Court noted the factual examination done by the Commissioner of Income Tax (Appeals) regarding the share capital of the companies involved. It found that the share capital raised by one of the companies in the assessment year 2009-10 had already been added back in the hands of the party, indicating its genuineness. The Court upheld the action of the Commissioner of Income Tax (Appeals) and ITAT in deleting the additions.
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