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 assessee received Rs. 125 lacs in cash from SGCFCL for facilitation work, which was not recorded in the books. The assessee claimed the amount was paid to 2500 shareholders, but failed to provide evidence of such payments. The onus was on the assessee to prove the impugned payment did not constitute income, which the assessee failed to discharge. The assessment was based on incriminating material and the assessee's statement admitting receipt of cash payment. The Appellate Tribunal upheld the assessment, rejecting the assessee's arguments.
The assessee received Rs. 125 lacs in cash from SGCFCL for facilitation work, which was not recorded in the books. The assessee claimed the amount was paid to 2500 shareholders, but failed to provide evidence of such payments. The onus was on the assessee to prove the impugned payment did not constitute income, which the assessee failed to discharge. The assessment was based on incriminating material and the assessee's statement admitting receipt of cash payment. The Appellate Tribunal upheld the assessment, rejecting the assessee's arguments.
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