Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Additions for cash receipts found during survey were unsustainable where the impugned receipts related to land owned and sold by a partnership firm, the advances were recorded in the firm's books as advances for sale of flats, and the firm had offered the corresponding income to tax; absent contrary evidence showing the transactions belonged to the individual taxpayer, the addition as the taxpayer's income was deleted. Additions based on impounded documents recording transactions in the taxpayer's name were likewise deleted because, on identical facts, the transactions were held to pertain to the partnership firm and to be accounted for as advances in the firm's books, rendering assessment in the taxpayer's hands impermissible. - ITAT
Additions for cash receipts found during survey were unsustainable where the impugned receipts related to land owned and sold by a partnership firm, the advances were recorded in the firm's books as advances for sale of flats, and the firm had offered the corresponding income to tax; absent contrary evidence showing the transactions belonged to the individual taxpayer, the addition as the taxpayer's income was deleted. Additions based on impounded documents recording transactions in the taxpayer's name were likewise deleted because, on identical facts, the transactions were held to pertain to the partnership firm and to be accounted for as advances in the firm's books, rendering assessment in the taxpayer's hands impermissible. - ITAT
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