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...
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The ITAT Delhi addressed the validity of additions in an assessment u/s 153A without incriminating material post a search u/s 132. Citing Abhisar Buildwell (P) Ltd., the Tribunal held that if no incriminating material is found during a search, the AO cannot assess or reassess completed/unabated assessments. Consequently, additions made without such material cannot stand. The Tribunal deleted the additions by the AO, including commission income, as they lacked a basis in incriminating material. Ground no. 1 was allowed in favor of the assessee.
The ITAT Delhi addressed the validity of additions in an assessment u/s 153A without incriminating material post a search u/s 132. Citing Abhisar Buildwell (P) Ltd., the Tribunal held that if no incriminating material is found during a search, the AO cannot assess or reassess completed/unabated assessments. Consequently, additions made without such material cannot stand. The Tribunal deleted the additions by the AO, including commission income, as they lacked a basis in incriminating material. Ground no. 1 was allowed in favor of the assessee.
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