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...
Loose sheets recovered in search can carry evidentiary value in income-tax proceedings when they contain contemporaneous transaction details and are fairly corroborated; the statutory presumption against the assessee applied, and a bare denial that the entries were not in the assessee's handwriting was insufficient to rebut it, so the additions based on undisclosed investment were sustained. Excess jewellery claimed as business stock failed on facts because neither the accounts nor wealth-tax returns showed it as stock-in-trade, so it was treated as undisclosed investment. Telescoping of unexplained cash was disallowed because the source of the cash was not satisfactorily established. The Tribunal's common order was upheld and the appeals were dismissed.
Loose sheets recovered in search can carry evidentiary value in income-tax proceedings when they contain contemporaneous transaction details and are fairly corroborated; the statutory presumption against the assessee applied, and a bare denial that the entries were not in the assessee's handwriting was insufficient to rebut it, so the additions based on undisclosed investment were sustained. Excess jewellery claimed as business stock failed on facts because neither the accounts nor wealth-tax returns showed it as stock-in-trade, so it was treated as undisclosed investment. Telescoping of unexplained cash was disallowed because the source of the cash was not satisfactorily established. The Tribunal's common order was upheld and the appeals were dismissed.
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