Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Addition under s.69A for cash deposits was challenged on the ground that the source was unproved. The assessee explained the deposits as arising from painting sales, sale of a portion of ancestral jewellery belonging to the mother supported by a valuation report, and cash gifts received by the son at his engagement, and furnished a cash-flow statement. The appellate authority accepted these explanations as consistent with ordinary human conduct and not disproportionate, and found the supporting evidence credible. As the Revenue only raised doubts on probabilities without rebutting the factual findings or evidence, interference was declined and deletion of the addition was upheld; the Revenue's appeal was dismissed - ITAT
Addition under s.69A for cash deposits was challenged on the ground that the source was unproved. The assessee explained the deposits as arising from painting sales, sale of a portion of ancestral jewellery belonging to the mother supported by a valuation report, and cash gifts received by the son at his engagement, and furnished a cash-flow statement. The appellate authority accepted these explanations as consistent with ordinary human conduct and not disproportionate, and found the supporting evidence credible. As the Revenue only raised doubts on probabilities without rebutting the factual findings or evidence, interference was declined and deletion of the addition was upheld; the Revenue's appeal was dismissed - ITAT
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