Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
In a transfer pricing dispute concerning the software development services segment, the ITAT held that the Transfer Pricing Officer had not dealt with the five comparables remitted for reconsideration, and that the later DRP consideration did not cure the failure to follow the earlier appellate direction in time. The defect was treated as an irregularity requiring correction, not as a basis to annul the assessment. The Assessing Officer was therefore directed to exclude Acropetal Technologies, E-Zest Solutions, E-Infochips, ICRA Techno Analytics and Persistent Systems and recompute the arm's length price adjustment; the assessment was otherwise left undisturbed.
In a transfer pricing dispute concerning the software development services segment, the ITAT held that the Transfer Pricing Officer had not dealt with the five comparables remitted for reconsideration, and that the later DRP consideration did not cure the failure to follow the earlier appellate direction in time. The defect was treated as an irregularity requiring correction, not as a basis to annul the assessment. The Assessing Officer was therefore directed to exclude Acropetal Technologies, E-Zest Solutions, E-Infochips, ICRA Techno Analytics and Persistent Systems and recompute the arm's length price adjustment; the assessment was otherwise left undisturbed.
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