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...
Deemed income assessment under section 69A was sustained where the AO established that the assessee had introduced and facilitated opening of 9,165 bank accounts and withdrawals from those accounts; the onus rested on the assessee to prove the nature and source of the unexplained amounts and it failed to do so. The Tribunal held ownership of withdrawn amounts as an indicium of income and rejected the CIT(A)'s finding that the assessee was merely a facilitator and not responsible for irregular accounts, thereby confirming additions for the assessment year.
Deemed income assessment under section 69A was sustained where the AO established that the assessee had introduced and facilitated opening of 9,165 bank accounts and withdrawals from those accounts; the onus rested on the assessee to prove the nature and source of the unexplained amounts and it failed to do so. The Tribunal held ownership of withdrawn amounts as an indicium of income and rejected the CIT(A)'s finding that the assessee was merely a facilitator and not responsible for irregular accounts, thereby confirming additions for the assessment year.
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