Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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In unabated assessments, additions under section 153A must rest on year-specific incriminating material; the Tribunal held that a loose sheet containing only rough notings, unrelated to the relevant assessment years, could not support presumed receipt of unaccounted cash from property sales, and the additions were deleted. It also held that section 69A could not apply where the assessee was not shown as buyer, seller, confirming party or beneficiary, and the receipts were plausibly explained as brokerage-related signatures without any corroborative evidence of ownership, possession or cash flow to the assessee. Both surviving additions were therefore unsustainable and were deleted.
In unabated assessments, additions under section 153A must rest on year-specific incriminating material; the Tribunal held that a loose sheet containing only rough notings, unrelated to the relevant assessment years, could not support presumed receipt of unaccounted cash from property sales, and the additions were deleted. It also held that section 69A could not apply where the assessee was not shown as buyer, seller, confirming party or beneficiary, and the receipts were plausibly explained as brokerage-related signatures without any corroborative evidence of ownership, possession or cash flow to the assessee. Both surviving additions were therefore unsustainable and were deleted.
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