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 Appellate Tribunal held that the addition u/s 56(2)(vii) or 28(iv) was unjustified, as the purchase was made with consideration, cheques were given to sellers with some not cleared due to property litigation. The addition u/s 69 for unexplained deposits was deleted, as cash withdrawals from one bank provided a source for deposits in another, AO's reasons were vague. The addition for cash-receipts as unexplained was also deleted, as taxable receipts were part of sale-proceeds duly assessed. Addition on account of cash-receipt for Godamaru was deleted, as money was refunded due to deal cancellation. The issue of advance for Badwai was remitted to AO for verification in a subsequent assessment year.
The Appellate Tribunal held that the addition u/s 56(2)(vii) or 28(iv) was unjustified, as the purchase was made with consideration, cheques were given to sellers with some not cleared due to property litigation. The addition u/s 69 for unexplained deposits was deleted, as cash withdrawals from one bank provided a source for deposits in another, AO's reasons were vague. The addition for cash-receipts as unexplained was also deleted, as taxable receipts were part of sale-proceeds duly assessed. Addition on account of cash-receipt for Godamaru was deleted, as money was refunded due to deal cancellation. The issue of advance for Badwai was remitted to AO for verification in a subsequent assessment year.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
