S. 92C: Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Captive software development services-Business closed after expiry of service agreement-Adjustment cannot be made on expenses incurred for closure of operations-Notional income not taxable.[S.92CA]
S. 92C: Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Advertisement, Marketing and Promotion (AMP) expenditure-Revenue failed to establish existence of international transaction-No transfer pricing adjustment-Information Technology support services-Separate international transaction-Matter remanded for fresh benchmarking.[S.92, 92B,92CA, 92F]
S. 69A: Unexplained money-Cash deposits during demonetisation-Cash generated from additional income disclosed before Settlement Commission-Source explained-Addition deleted.
S. 69A: Unexplained money-Search assessment-Financial broker-Cash loans belonging to clients-Brokerage income already disclosed-Addition as unexplained money deleted-Seized document-Entire document to be read as a whole-Revenue cannot rely selectively on favourable entries.[S.69A, 132, 132(4), 153C]
S. 68: Cash credits-Loans received by non-banking financial company-Identity, creditworthiness and genuineness established-Running account between parties-Addition deleted.
S. 68: Cash credits-Share capital and share premium-Identity, creditworthiness and genuineness established-No incriminating material found during search-Addition deleted.[S. 132]
S. 68: Cash credits-Loan repaid through account payee cheques-Documentary evidence ignored-Addition deleted-Unexplained investment-Purchase of immovable property-Source partly explained-Addition restricted.[S.69]
S. 68: Cash credits-Unsecured loans-Repayment through banking channels accepted in subsequent year-Addition of loans, commission and interest deleted.
S. 56: Income from other sources-Shares held as stock-in-trade-Purchase below fair market value-Provision not applicable.[S. 2(14), 56(2)(vii) R. 11UA]
S. 50C: Capital gains-Full value of consideration-Stamp valuation Mandatory reference to Valuation Officer ignored-Additions deleted.[S. 56(2)(vii)(b)]