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...
CIT(A) determined profit at 5.47% on total purchases. Assessee produced sufficient evidence regarding purchases, movement of goods, GST payment on transportation, expenses accounted for. No evidence of routing back payments. CIT(A) endorsed assessee's contentions but erred in directing gross profit rate application, defying logic. Assessee discharged onus, furnished abundant evidence substantiating purchases' genuineness. CIT(A) erred in sustaining gross profit addition on alleged purchases over declared profit. Gross profit determined by CIT(A) directed to be deleted. Addition u/s 56(2)(x) for difference between purchase price and stamp duty value of property purchased, without referring valuation to DVO, is unsustainable and liable to be deleted. AO bound to refer valuation to DVO when assessee disputes stamp duty value. Addition by AO and confirmation by CIT(A), without DVO reference, unsustainable and deleted in assessee's favor.
CIT(A) determined profit at 5.47% on total purchases. Assessee produced sufficient evidence regarding purchases, movement of goods, GST payment on transportation, expenses accounted for. No evidence of routing back payments. CIT(A) endorsed assessee's contentions but erred in directing gross profit rate application, defying logic. Assessee discharged onus, furnished abundant evidence substantiating purchases' genuineness. CIT(A) erred in sustaining gross profit addition on alleged purchases over declared profit. Gross profit determined by CIT(A) directed to be deleted. Addition u/s 56(2)(x) for difference between purchase price and stamp duty value of property purchased, without referring valuation to DVO, is unsustainable and liable to be deleted. AO bound to refer valuation to DVO when assessee disputes stamp duty value. Addition by AO and confirmation by CIT(A), without DVO reference, unsustainable and deleted in assessee's favor.
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