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...
Authorities disallowed purchases as 'bogus' on the premise that the assessee failed to prove genuineness, but ignored extensive documentary material (confirmations, bills, lorry receipts, ledgers, bank statements, returns and accounts) filed during assessment. The decision emphasises that where authorities record a factual finding of non-production yet fail to consider or verify available documents, the audi alteram partem principle and statutory duty to evaluate submissions are breached; accordingly the impugned disallowance cannot stand and the addition was set aside and deleted for want of proper verification and consideration.
Authorities disallowed purchases as 'bogus' on the premise that the assessee failed to prove genuineness, but ignored extensive documentary material (confirmations, bills, lorry receipts, ledgers, bank statements, returns and accounts) filed during assessment. The decision emphasises that where authorities record a factual finding of non-production yet fail to consider or verify available documents, the audi alteram partem principle and statutory duty to evaluate submissions are breached; accordingly the impugned disallowance cannot stand and the addition was set aside and deleted for want of proper verification and consideration.
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