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...
Cash deposit during demonetization period treated as unexplained cash credit u/s 68 - CIT(A) sustained addition u/s 69A based on lack of supporting evidence for cash receipts from nursing home. Assessee's claim of maintaining regular books and audit u/s 44AB not sufficient. Tribunal remanded for fresh examination by AO in light of precedent on abnormal cash trails indicating suspicion. Unsecured loan receipts - assessee failed to prove genuineness and creditworthiness of lenders. Remanded to AO for independent enquiry and decision after giving assessee opportunity. Addition as agricultural income - assessee's claim of acceptance in earlier years rejected as res judicata not applicable. Remanded to AO to examine evidence of agricultural income for the year. AO to follow principles of natural justice, fairness and preponderance of probabilities in enquiries.
Cash deposit during demonetization period treated as unexplained cash credit u/s 68 - CIT(A) sustained addition u/s 69A based on lack of supporting evidence for cash receipts from nursing home. Assessee's claim of maintaining regular books and audit u/s 44AB not sufficient. Tribunal remanded for fresh examination by AO in light of precedent on abnormal cash trails indicating suspicion. Unsecured loan receipts - assessee failed to prove genuineness and creditworthiness of lenders. Remanded to AO for independent enquiry and decision after giving assessee opportunity. Addition as agricultural income - assessee's claim of acceptance in earlier years rejected as res judicata not applicable. Remanded to AO to examine evidence of agricultural income for the year. AO to follow principles of natural justice, fairness and preponderance of probabilities in enquiries.
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