Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
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The assessing officer made protective additions u/ss 69, 69C, and 68 for amounts already considered by the firm where the assessee was a partner. However, the settlement commission's order dated 03.12.2020, containing entries from serial numbers 1 to 2402 for which additions were made by the assessing officer on a protective basis, was not disputed by the revenue. Since the additions accepted by the firm were not contested by the revenue, they cannot be sustained in the assessee's hands on a protective basis. Consequently, the ground raised by the assessee stands allowed by the Income Tax Appellate Tribunal.
The assessing officer made protective additions u/ss 69, 69C, and 68 for amounts already considered by the firm where the assessee was a partner. However, the settlement commission's order dated 03.12.2020, containing entries from serial numbers 1 to 2402 for which additions were made by the assessing officer on a protective basis, was not disputed by the revenue. Since the additions accepted by the firm were not contested by the revenue, they cannot be sustained in the assessee's hands on a protective basis. Consequently, the ground raised by the assessee stands allowed by the Income Tax Appellate Tribunal.
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