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 271G for failure to furnish transfer pricing documentation could not survive once the underlying transfer pricing adjustment had been deleted and that deletion had been affirmed. The Tribunal held that, with the foundation of the penalty proceedings removed, there was no basis to sustain the penalty on the same transaction. The Revenue's challenge to deletion of the penalty failed, and the appellate order was upheld. The assessee's cross-objection was dismissed as infructuous because the remaining grounds had become academic.
Penalty under section 271G for failure to furnish transfer pricing documentation could not survive once the underlying transfer pricing adjustment had been deleted and that deletion had been affirmed. The Tribunal held that, with the foundation of the penalty proceedings removed, there was no basis to sustain the penalty on the same transaction. The Revenue's challenge to deletion of the penalty failed, and the appellate order was upheld. The assessee's cross-objection was dismissed as infructuous because the remaining grounds had become academic.
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