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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Additions for unexplained money failed where the Revenue relied on presumption without independent corroboration. For the alleged cash payment to or on behalf of Ms. Jwala Gutta, the Tribunal found that the seized material did not establish that the assessee himself made any cash payment, and there was no confirmation from Ms. Gutta or other supporting evidence; the addition was deleted. For the alleged cash component of marriage expenses, the Assessing Officer made no enquiry from the recipient and did not properly examine the possibility of funding from Shagun receipts, so the addition was also deleted. The Tribunal treated both additions as unsupported by evidence and allowed the appeal, with the same view applied to the other assessment years.
Additions for unexplained money failed where the Revenue relied on presumption without independent corroboration. For the alleged cash payment to or on behalf of Ms. Jwala Gutta, the Tribunal found that the seized material did not establish that the assessee himself made any cash payment, and there was no confirmation from Ms. Gutta or other supporting evidence; the addition was deleted. For the alleged cash component of marriage expenses, the Assessing Officer made no enquiry from the recipient and did not properly examine the possibility of funding from Shagun receipts, so the addition was also deleted. The Tribunal treated both additions as unsupported by evidence and allowed the appeal, with the same view applied to the other assessment years.
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