Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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HC allowed the petitioner's appeal, quashing the AO's reassessment order under Section 148A(d). The court found the order was passed without application of mind, highlighting internal contradictions where the AO first acknowledged the income tax return's filing, then subsequently claimed no return was submitted. The decision emphasized the petitioner's submission of bank statements documenting funds borrowed from his father for cryptocurrency purchase, which were undisputed. The reassessment order was deemed legally unsustainable and was set aside, providing relief to the taxpayer by invalidating the reopening of the assessment.
HC allowed the petitioner's appeal, quashing the AO's reassessment order under Section 148A(d). The court found the order was passed without application of mind, highlighting internal contradictions where the AO first acknowledged the income tax return's filing, then subsequently claimed no return was submitted. The decision emphasized the petitioner's submission of bank statements documenting funds borrowed from his father for cryptocurrency purchase, which were undisputed. The reassessment order was deemed legally unsustainable and was set aside, providing relief to the taxpayer by invalidating the reopening of the assessment.
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