Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Unaccounted production addition was deleted because the comparison made by the AO was between unlike units, treating tablets/capsules in production charts as if they were strips in sales records. The Court accepted the concurrent findings of the CIT(A) and Tribunal that this erroneous comparison made the computation unsustainable. It also noted that there was no corroborative material showing excess raw material purchases, unaccounted manufacturing expenditure, or receipt of unaccounted sale proceeds, even after search. The Revenue's challenge was therefore confined to factual issues, and the appeal was dismissed for want of any substantial question of law.
Unaccounted production addition was deleted because the comparison made by the AO was between unlike units, treating tablets/capsules in production charts as if they were strips in sales records. The Court accepted the concurrent findings of the CIT(A) and Tribunal that this erroneous comparison made the computation unsustainable. It also noted that there was no corroborative material showing excess raw material purchases, unaccounted manufacturing expenditure, or receipt of unaccounted sale proceeds, even after search. The Revenue's challenge was therefore confined to factual issues, and the appeal was dismissed for want of any substantial question of law.
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