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...
Penalty under section 271(1)(c) was held unsustainable where the disallowance arose from a deduction claim under section 80IB(10) on which courts had taken divergent views. The Tribunal treated the issue as debatable, noted that the controversy was pending before the Supreme Court, and applied Reliance Petroproducts to hold that a merely unsustainable claim does not amount to concealment or furnishing inaccurate particulars. On that basis, the statutory conditions for penalty were not met and the penalty was deleted.
Penalty under section 271(1)(c) was held unsustainable where the disallowance arose from a deduction claim under section 80IB(10) on which courts had taken divergent views. The Tribunal treated the issue as debatable, noted that the controversy was pending before the Supreme Court, and applied Reliance Petroproducts to hold that a merely unsustainable claim does not amount to concealment or furnishing inaccurate particulars. On that basis, the statutory conditions for penalty were not met and the penalty was deleted.
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