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...
Reopening assessment u/s 148 upheld based on specific information from DDIT (Inv) about transactions with M/s Vishnu Trading Co, providing reasonable belief of escaped income. Addition u/s 68 as unexplained cash credits deleted as books not rejected, quantitative details provided, and lack of evidence of accommodation entries. Cross-examination opportunity denied, violating natural justice principles. Transactions with M/s Edelweiss Commodities misunderstood. Consequential deletion of taxation u/s 115BBE, interest u/ss 234A, 234B, 234C, 234D, and penalty u/s 271(1)(c).
Reopening assessment u/s 148 upheld based on specific information from DDIT (Inv) about transactions with M/s Vishnu Trading Co, providing reasonable belief of escaped income. Addition u/s 68 as unexplained cash credits deleted as books not rejected, quantitative details provided, and lack of evidence of accommodation entries. Cross-examination opportunity denied, violating natural justice principles. Transactions with M/s Edelweiss Commodities misunderstood. Consequential deletion of taxation u/s 115BBE, interest u/ss 234A, 234B, 234C, 234D, and penalty u/s 271(1)(c).
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