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 Tribunal upheld deletion of section 68 additions for unsecured loans because the assessee produced confirmations, ledger accounts, income-tax returns, financial statements and bank statements showing identity, creditworthiness and genuineness, with receipts routed through banking channels and no rebuttal by the Revenue. It also accepted telescoping where the cash used for cheque-against-cash entries was linked to an already taxed on-money stream, so the related principal and interest additions did not survive. On disallowance of interest for diversion of borrowed funds, the Tribunal sustained only the reduced amount after finding no error in the appellate working of interest-free funds and advances.
The Tribunal upheld deletion of section 68 additions for unsecured loans because the assessee produced confirmations, ledger accounts, income-tax returns, financial statements and bank statements showing identity, creditworthiness and genuineness, with receipts routed through banking channels and no rebuttal by the Revenue. It also accepted telescoping where the cash used for cheque-against-cash entries was linked to an already taxed on-money stream, so the related principal and interest additions did not survive. On disallowance of interest for diversion of borrowed funds, the Tribunal sustained only the reduced amount after finding no error in the appellate working of interest-free funds and advances.
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