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...
Assessment u/s 153A - unexplained investment in Hotel Building - addition under sec 69 r.w.s. 115BBE - reliance on DVO report post-search - Held, DVO report estimation-based, no incriminating material found during search, addition not valid. Rejection of books u/s 145(3) - difference in investment amount, books not rejected due to deletion of difference. Disallowance of current year business loss - unjustified due to sustainable books rejection. Disallowance u/s 35AD - hotel building expenditure - 4-star rating obtained, qualifies for deduction, AO's misinterpretation rejected, claim allowed.
Assessment u/s 153A - unexplained investment in Hotel Building - addition under sec 69 r.w.s. 115BBE - reliance on DVO report post-search - Held, DVO report estimation-based, no incriminating material found during search, addition not valid. Rejection of books u/s 145(3) - difference in investment amount, books not rejected due to deletion of difference. Disallowance of current year business loss - unjustified due to sustainable books rejection. Disallowance u/s 35AD - hotel building expenditure - 4-star rating obtained, qualifies for deduction, AO's misinterpretation rejected, claim allowed.
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