Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Hybrid seed production on leased agricultural land was treated as agricultural income because the assessee had exclusive use and beneficial control of the land, supervised cultivation, bore the cultivation risk, and owned the produce; use of technical methods did not change the agricultural character, so the addition as business income was deleted. Trade creditors for professional and compliance expenses were held outside section 68 because they were not loan credits and were later paid through banking channels, so that addition was deleted. Balance differences in creditor confirmations were not taxable under section 69C or section 41(1) absent proof of remission or cessation of liability, so that addition was also deleted.
Hybrid seed production on leased agricultural land was treated as agricultural income because the assessee had exclusive use and beneficial control of the land, supervised cultivation, bore the cultivation risk, and owned the produce; use of technical methods did not change the agricultural character, so the addition as business income was deleted. Trade creditors for professional and compliance expenses were held outside section 68 because they were not loan credits and were later paid through banking channels, so that addition was deleted. Balance differences in creditor confirmations were not taxable under section 69C or section 41(1) absent proof of remission or cessation of liability, so that addition was also deleted.
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