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...
Undisclosed receipts were added to gross profit by the AO, but the assessee claimed corresponding expenditure. CIT(A) deleted the addition, terming it double assessment. The department did not rebut that the addition was double assessment or deny the corresponding expenditure. ITAT held that the AO could not brush aside the assessee's claim of corresponding expenditure, which was duly considered by CIT(A). The department's grounds did not dispute the correctness of the expenditure items. The addition was rejected accordingly.
Undisclosed receipts were added to gross profit by the AO, but the assessee claimed corresponding expenditure. CIT(A) deleted the addition, terming it double assessment. The department did not rebut that the addition was double assessment or deny the corresponding expenditure. ITAT held that the AO could not brush aside the assessee's claim of corresponding expenditure, which was duly considered by CIT(A). The department's grounds did not dispute the correctness of the expenditure items. The addition was rejected accordingly.
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