Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Revision under s.263 was upheld on the ground that the assessment allowing deduction u/s 80G without enquiry into an allegedly bogus donation was erroneous and prejudicial to revenue. Mere production of a donation receipt was held insufficient to establish genuineness, especially when the Department possessed search-derived information indicating the donee entity's involvement in providing accommodation donations. Applying Explanation 2 to s.263, failure to conduct the necessary verification rendered the assessment order deemed erroneous; consequently, the revisional authority's direction for proper examination was sustained and the assessee's appeal was dismissed. - ITAT
Revision under s.263 was upheld on the ground that the assessment allowing deduction u/s 80G without enquiry into an allegedly bogus donation was erroneous and prejudicial to revenue. Mere production of a donation receipt was held insufficient to establish genuineness, especially when the Department possessed search-derived information indicating the donee entity's involvement in providing accommodation donations. Applying Explanation 2 to s.263, failure to conduct the necessary verification rendered the assessment order deemed erroneous; consequently, the revisional authority's direction for proper examination was sustained and the assessee's appeal was dismissed. - ITAT
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