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...
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Recorded bank credits supported by books of account, confirmations, returns, ledgers and bank statements could not be treated as unexplained money under section 69A, because the assessee was not shown to be the owner of unrecorded money and the addition lacked corroborative evidence that the funds were undisclosed income. The deletion of the addition, including the cash deposit component, was upheld. Reassessment also failed because the recorded reasons rested on incorrect facts: the assessee was said to have three bank accounts and higher non-cash credits, but verification showed only one bank account and the alleged information was wrong. The section 148 notice and reassessment proceedings were therefore held unsustainable.
Recorded bank credits supported by books of account, confirmations, returns, ledgers and bank statements could not be treated as unexplained money under section 69A, because the assessee was not shown to be the owner of unrecorded money and the addition lacked corroborative evidence that the funds were undisclosed income. The deletion of the addition, including the cash deposit component, was upheld. Reassessment also failed because the recorded reasons rested on incorrect facts: the assessee was said to have three bank accounts and higher non-cash credits, but verification showed only one bank account and the alleged information was wrong. The section 148 notice and reassessment proceedings were therefore held unsustainable.
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