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 challenged on the ground that reasons to believe lacked a live evidentiary link between seized materials and the assessee; the AO relied on statements and a brokers register suggesting a cash on money component and a unit rate, but those documents did not name the co-owner or the assessee. The AOs computation accepted the assessees 30% share, yet the asserted intent to sell the entire plot earlier conflicted with subsequent gift transactions by the co-owner. For lack of independent corroborative material connecting the assessee to the alleged on-money transaction, the impugned notice was quashed.
Reopening of assessment challenged on the ground that reasons to believe lacked a live evidentiary link between seized materials and the assessee; the AO relied on statements and a brokers register suggesting a cash on money component and a unit rate, but those documents did not name the co-owner or the assessee. The AOs computation accepted the assessees 30% share, yet the asserted intent to sell the entire plot earlier conflicted with subsequent gift transactions by the co-owner. For lack of independent corroborative material connecting the assessee to the alleged on-money transaction, the impugned notice was quashed.
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