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...
Interest under section 234B was held not leviable where the assessee computed and paid advance tax in accordance with the law then in force, and the shortfall arose only because ICDS applicability was later deferred by a retrospective legal change. The Tribunal held that default in advance tax must be tested on the basis of the law existing when the assessee was required to estimate current income and pay advance tax. Since the later change was not foreseeable at the relevant time, the assessee could not be treated as in default, and the interest demand was deleted.
Interest under section 234B was held not leviable where the assessee computed and paid advance tax in accordance with the law then in force, and the shortfall arose only because ICDS applicability was later deferred by a retrospective legal change. The Tribunal held that default in advance tax must be tested on the basis of the law existing when the assessee was required to estimate current income and pay advance tax. Since the later change was not foreseeable at the relevant time, the assessee could not be treated as in default, and the interest demand was deleted.
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