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...
The ITAT Delhi addressed the taxability of certain creditors as unexplained liabilities. It was found that liabilities of G.G.Telecrest Pvt. Ltd. and Uttam Strips Pvt. Ltd. should be classified as loans/advances, not creditors. The liabilities of these parties require further investigation. The issue was remitted back to the AO for reconsideration. For other creditors, where no details or confirmation were provided, the addition was upheld. Disallowance of commission expenses u/s 40(a)(ia) and taxability of cash deposits were also addressed, with the findings of the CIT(A) upheld due to lack of contradicting evidence. The appeal of the assessee was partly allowed.
The ITAT Delhi addressed the taxability of certain creditors as unexplained liabilities. It was found that liabilities of G.G.Telecrest Pvt. Ltd. and Uttam Strips Pvt. Ltd. should be classified as loans/advances, not creditors. The liabilities of these parties require further investigation. The issue was remitted back to the AO for reconsideration. For other creditors, where no details or confirmation were provided, the addition was upheld. Disallowance of commission expenses u/s 40(a)(ia) and taxability of cash deposits were also addressed, with the findings of the CIT(A) upheld due to lack of contradicting evidence. The appeal of the assessee was partly allowed.
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