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) could not be sustained where society charges and depreciation were disallowed only for want of supporting evidence or by following earlier years, because the claims were fully disclosed in the books and return and no false or inaccurate particulars were found. In an unabated year, additions under section 153C could not rest on routine disallowances without incriminating material. The Tribunal upheld deletion of the penalty, and the Revenue's challenge failed.
Penalty under section 271(1)(c) could not be sustained where society charges and depreciation were disallowed only for want of supporting evidence or by following earlier years, because the claims were fully disclosed in the books and return and no false or inaccurate particulars were found. In an unabated year, additions under section 153C could not rest on routine disallowances without incriminating material. The Tribunal upheld deletion of the penalty, and the Revenue's challenge failed.
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