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...
Alleged embezzlement/misappropriation payments were not allowable as business expenditure because the assessee adopted contradictory characterisations, produced no agreements, bills or particulars identifying the role or benefit to the alleged misappropriator, and did not pursue recovery; the Tribunal's disallowance was sustained. Payments to a partner's relative were disallowed under the provision permitting the assessing officer to strike down excessive or unreasonable related party payments in absence of documentary support; that application was upheld. Reassessment was within limitation because the escaped income exceeded the statutory threshold, bringing the longer limitation period into play; the notice was therefore valid and the appeal dismissed.
Alleged embezzlement/misappropriation payments were not allowable as business expenditure because the assessee adopted contradictory characterisations, produced no agreements, bills or particulars identifying the role or benefit to the alleged misappropriator, and did not pursue recovery; the Tribunal's disallowance was sustained. Payments to a partner's relative were disallowed under the provision permitting the assessing officer to strike down excessive or unreasonable related party payments in absence of documentary support; that application was upheld. Reassessment was within limitation because the escaped income exceeded the statutory threshold, bringing the longer limitation period into play; the notice was therefore valid and the appeal dismissed.
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