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...
Reopening of assessment was upheld where impounded loose papers and a purchaser's admission provided prima facie material of undisclosed cash consideration, corroborated by matching cheque entries and registered sale deeds; failure of the assessee to specifically seek cross examination at reassessment foreclosed a later natural justice challenge. The impounded documents were treated as reliable corroborative evidence rather than vague papers, and the existence of substantial disparity between recorded and apparent market value reinforced inference of on money. On these grounds the assessing officer's addition as unaccounted sale consideration was held justified and the claim against reassessment failed.
Reopening of assessment was upheld where impounded loose papers and a purchaser's admission provided prima facie material of undisclosed cash consideration, corroborated by matching cheque entries and registered sale deeds; failure of the assessee to specifically seek cross examination at reassessment foreclosed a later natural justice challenge. The impounded documents were treated as reliable corroborative evidence rather than vague papers, and the existence of substantial disparity between recorded and apparent market value reinforced inference of on money. On these grounds the assessing officer's addition as unaccounted sale consideration was held justified and the claim against reassessment failed.
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