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...
Reopening of assessment was challenged on the ground that the assessing officer had accepted the assessee's explanation regarding the source of investment in property. The tribunal relied on precedent to conclude that once the AO accepted the explanation recorded in reasons, the AO lacked basis to make an independent addition in respect of that subject-matter. Consequently, the addition made in the assessment was deleted and the assessment adjustment was set aside in favour of the assessee.
Reopening of assessment was challenged on the ground that the assessing officer had accepted the assessee's explanation regarding the source of investment in property. The tribunal relied on precedent to conclude that once the AO accepted the explanation recorded in reasons, the AO lacked basis to make an independent addition in respect of that subject-matter. Consequently, the addition made in the assessment was deleted and the assessment adjustment was set aside in favour of the assessee.
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