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...
The ITAT found that the addition relating to alleged immovable property transactions was made without proper verification of the basic facts, particularly because the assessment record showed inconsistency in how the same properties were treated and the AO had shifted between possible taxability under section 56(2)(x) and section 50C. The Tribunal noted that no addition was ultimately made under section 56(2)(x), while the section 50C addition rested on an unverified factual foundation, and the assessee's cancellation claim was unsupported by the record. The matter was therefore restored to the jurisdictional AO for fresh examination and re-adjudication on evidence and enquiry.
The ITAT found that the addition relating to alleged immovable property transactions was made without proper verification of the basic facts, particularly because the assessment record showed inconsistency in how the same properties were treated and the AO had shifted between possible taxability under section 56(2)(x) and section 50C. The Tribunal noted that no addition was ultimately made under section 56(2)(x), while the section 50C addition rested on an unverified factual foundation, and the assessee's cancellation claim was unsupported by the record. The matter was therefore restored to the jurisdictional AO for fresh examination and re-adjudication on evidence and enquiry.
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