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...
Reopening under reassessment provisions was upheld where the Assessing Officer relied on tangible seized material, printouts and a statement recorded during GST proceedings plus information from a third party, providing a prima facie basis to form belief that income escaped assessment; retraction of the statement did not, absent evidence of coercion, negate the seized material and did not vitiate the reopening. The revenue's adoption of the valuation determined by CGST/Central Excise was accepted in the assessee's hands, and a conservative job work charge at the lower end of the 4%-12% market range (adjusted for diamonds) was sustained.
Reopening under reassessment provisions was upheld where the Assessing Officer relied on tangible seized material, printouts and a statement recorded during GST proceedings plus information from a third party, providing a prima facie basis to form belief that income escaped assessment; retraction of the statement did not, absent evidence of coercion, negate the seized material and did not vitiate the reopening. The revenue's adoption of the valuation determined by CGST/Central Excise was accepted in the assessee's hands, and a conservative job work charge at the lower end of the 4%-12% market range (adjusted for diamonds) was sustained.
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