Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Presumptive taxation: where an assessee opts to declare income under the presumptive scheme and offers income accordingly, separate additions for unexplained cash bank deposits cannot be sustained; the tribunal relied on precedent holding that opting into the presumptive regime removes the obligation to explain each cash entry, and directed deletion of the addition. The appellate authority allowed the assessee's appeal and set aside the lower appellate order that had limited relief to bank debits, restoring complete relief against the addition by the assessing officer.
Presumptive taxation: where an assessee opts to declare income under the presumptive scheme and offers income accordingly, separate additions for unexplained cash bank deposits cannot be sustained; the tribunal relied on precedent holding that opting into the presumptive regime removes the obligation to explain each cash entry, and directed deletion of the addition. The appellate authority allowed the assessee's appeal and set aside the lower appellate order that had limited relief to bank debits, restoring complete relief against the addition by the assessing officer.
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