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...
ITAT upheld CIT(A)'s order, dismissing revenue's appeal regarding unexplained cash deposits under Section 68 and Section 115BBE. The tribunal found that the assessee substantiated the cash deposits through bank certificates and sales receipts from audited accounts. No contrary evidence was presented by the Assessing Officer challenging the source of deposits. Similarly, for disallowance under Section 40A(3), the tribunal confirmed CIT(A)'s deletion of addition due to lack of specific violation proof. The revenue's contentions were rejected, and the appeal was comprehensively dismissed.
ITAT upheld CIT(A)'s order, dismissing revenue's appeal regarding unexplained cash deposits under Section 68 and Section 115BBE. The tribunal found that the assessee substantiated the cash deposits through bank certificates and sales receipts from audited accounts. No contrary evidence was presented by the Assessing Officer challenging the source of deposits. Similarly, for disallowance under Section 40A(3), the tribunal confirmed CIT(A)'s deletion of addition due to lack of specific violation proof. The revenue's contentions were rejected, and the appeal was comprehensively dismissed.
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