Transaction value under s.15(1) governs unrelated sales; valuation between related parties per Rule 28; consignment note required for unregistered rec...
ITAT upheld the assessee's appeal and directed deletion of the addition treating receipts as income from FTS/FIS. The Tribunal found the payments arose under the same agreement dated 20.02.2017, covering software licence and ancillary support/AMC, and that the factual matrix identical to AY 2019-20 compelled the same conclusion as in the earlier ITAT decision relied upon by the assessee. The Revenue failed to adduce contrary material or distinguish the precedent. Consequently, the addition made by the AO is set aside and the grounds of appeal filed by the assessee are allowed.
ITAT upheld the assessee's appeal and directed deletion of the addition treating receipts as income from FTS/FIS. The Tribunal found the payments arose under the same agreement dated 20.02.2017, covering software licence and ancillary support/AMC, and that the factual matrix identical to AY 2019-20 compelled the same conclusion as in the earlier ITAT decision relied upon by the assessee. The Revenue failed to adduce contrary material or distinguish the precedent. Consequently, the addition made by the AO is set aside and the grounds of appeal filed by the assessee are allowed.
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