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...
Tribunal addressed estimated additions made by the AO over recorded purchase and sales without first rejecting the books of account under applicable provisions; it held that where the AO accepts the genuineness of books he cannot independently compute estimated unrecorded sales or commission income without invoking rejection/estimation provisions, and such additions are arbitrary and unlawful. The Tribunal directed deletion of the estimated addition and allowed the appeal, applying precedent that books must be rejected before making estimation-based additions.
Tribunal addressed estimated additions made by the AO over recorded purchase and sales without first rejecting the books of account under applicable provisions; it held that where the AO accepts the genuineness of books he cannot independently compute estimated unrecorded sales or commission income without invoking rejection/estimation provisions, and such additions are arbitrary and unlawful. The Tribunal directed deletion of the estimated addition and allowed the appeal, applying precedent that books must be rejected before making estimation-based additions.
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