Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Seized marketing 'welcome letters' and loose undated digital sheets were held insufficiently reliable to support additions for alleged suppression of sales absent signatures, buyer confirmations, bank-trace or other corroboration; extrapolation of undeclared sales by applying unauthenticated online portal asking rates was held speculative and inadmissible without seized evidence, buyer examination, comparable deeds or valuation; for unexplained cash credits the assessee discharged primary onus by producing identity, ledger entries, bank records and lender financials and repayments, and the AO failed to rebut with cogent material; approval by the range head for assessment proceedings was found to be non-mechanical. Operative effect: document-based and extrapolated additions and unexplained-loan additions were deleted, while approval validity was upheld.
Seized marketing 'welcome letters' and loose undated digital sheets were held insufficiently reliable to support additions for alleged suppression of sales absent signatures, buyer confirmations, bank-trace or other corroboration; extrapolation of undeclared sales by applying unauthenticated online portal asking rates was held speculative and inadmissible without seized evidence, buyer examination, comparable deeds or valuation; for unexplained cash credits the assessee discharged primary onus by producing identity, ledger entries, bank records and lender financials and repayments, and the AO failed to rebut with cogent material; approval by the range head for assessment proceedings was found to be non-mechanical. Operative effect: document-based and extrapolated additions and unexplained-loan additions were deleted, while approval validity was upheld.
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