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 affirmed CIT(A)'s order, rejecting revenue's appeal. The tribunal upheld the lower authority's findings on multiple legal issues: (1) assessee qualified for long-term capital gains tax exemption under Section 54F by owning only one residential house at share transfer date, (2) sale proceeds of gifted shares from son were not unexplained cash credit under Section 68, and (3) unsecured loans from family members with proper documentation were not assessable as unexplained income. The tribunal found no merit in revenue's contentions and dismissed the appeal, maintaining the original order that deleted additions made by the Assessing Officer.
ITAT affirmed CIT(A)'s order, rejecting revenue's appeal. The tribunal upheld the lower authority's findings on multiple legal issues: (1) assessee qualified for long-term capital gains tax exemption under Section 54F by owning only one residential house at share transfer date, (2) sale proceeds of gifted shares from son were not unexplained cash credit under Section 68, and (3) unsecured loans from family members with proper documentation were not assessable as unexplained income. The tribunal found no merit in revenue's contentions and dismissed the appeal, maintaining the original order that deleted additions made by the Assessing Officer.
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