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...
Reassessment under section 147/148 was quashed because applying the Assessing Officer's own gross profit rate (13.85%) produced alleged escaped income of Rs.48,09,503, below the statutory monetary threshold of Rs.50,00,000 under section 149(1)(b), and "income chargeable to tax which has escaped assessment" refers to real income, not gross transaction value. On merits, the assessee produced primary documents and bank payment evidence which AO did not independently test; books were not rejected under section 145(3), and a separate addition would duplicate profit already reflected in returned income. Appeal allowed by ITAT.
Reassessment under section 147/148 was quashed because applying the Assessing Officer's own gross profit rate (13.85%) produced alleged escaped income of Rs.48,09,503, below the statutory monetary threshold of Rs.50,00,000 under section 149(1)(b), and "income chargeable to tax which has escaped assessment" refers to real income, not gross transaction value. On merits, the assessee produced primary documents and bank payment evidence which AO did not independently test; books were not rejected under section 145(3), and a separate addition would duplicate profit already reflected in returned income. Appeal allowed by ITAT.
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