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...
ITAT held that estimated gross on-money receipts could not be taxed in full where the record also showed unaccounted funds being routed into the books as unsecured loans through the admitted modus operandi. Because the assessee failed to prove the genuineness and creditworthiness of the lenders, the unsecured loans were treated as unexplained and the CIT(A)'s restricted additions were sustained for the relevant assessment years. The Tribunal also rejected further telescoping based on income earlier declared, and upheld the CIT(A)'s approach as the correct basis of taxation. The Revenue's appeal and the assessee's appeals were dismissed.
ITAT held that estimated gross on-money receipts could not be taxed in full where the record also showed unaccounted funds being routed into the books as unsecured loans through the admitted modus operandi. Because the assessee failed to prove the genuineness and creditworthiness of the lenders, the unsecured loans were treated as unexplained and the CIT(A)'s restricted additions were sustained for the relevant assessment years. The Tribunal also rejected further telescoping based on income earlier declared, and upheld the CIT(A)'s approach as the correct basis of taxation. The Revenue's appeal and the assessee's appeals were dismissed.
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