Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Treatment of unaccounted investment in immovable property turned on whether a bank valuation report constituted incriminating material in a search assessment; appellate authority found no incriminating material and sustained deletion of additions disallowing reliance on that valuation. Separate STCG adjustment based on AO's adoption of the DVO estimate at 120% (20% escalation) was held to be a baseless simplicitor estimation; the appellate authority rejected the enhanced valuation and deleted the STCG addition accordingly.
Treatment of unaccounted investment in immovable property turned on whether a bank valuation report constituted incriminating material in a search assessment; appellate authority found no incriminating material and sustained deletion of additions disallowing reliance on that valuation. Separate STCG adjustment based on AO's adoption of the DVO estimate at 120% (20% escalation) was held to be a baseless simplicitor estimation; the appellate authority rejected the enhanced valuation and deleted the STCG addition accordingly.
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