Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Bogus long-term capital gains from penny stock transactions were rejected where contract notes, demat entries, bank records and sale documents did not establish genuineness. The Tribunal found that the scrip showed abnormal price movement unrelated to the company's financial position and business activity, the original purchase was through an off-market route in an unlisted company, and the assessee was not shown to be a regular or informed investor. Applying the human probabilities test, it treated the transaction as a pre-arranged accommodation entry mechanism to convert unaccounted income into exempt capital gains. The burden under section 68 was not discharged, the addition was upheld, and exemption under section 10(38) was denied.
Bogus long-term capital gains from penny stock transactions were rejected where contract notes, demat entries, bank records and sale documents did not establish genuineness. The Tribunal found that the scrip showed abnormal price movement unrelated to the company's financial position and business activity, the original purchase was through an off-market route in an unlisted company, and the assessee was not shown to be a regular or informed investor. Applying the human probabilities test, it treated the transaction as a pre-arranged accommodation entry mechanism to convert unaccounted income into exempt capital gains. The burden under section 68 was not discharged, the addition was upheld, and exemption under section 10(38) was denied.
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