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 for initial non-compliance with notices under section 142(1) was treated as unsustainable where the assessee later furnished replies and documentary evidence during assessment, and the return was accepted under section 143(3) without adverse inference. The assessment order recorded verification of the later compliance and found it tenable, which indicated that the earlier default had been effectively condoned. On the same facts, the same reasoning was applied to the connected matters, and the penalty under section 272A(1)(d) was deleted.
Penalty for initial non-compliance with notices under section 142(1) was treated as unsustainable where the assessee later furnished replies and documentary evidence during assessment, and the return was accepted under section 143(3) without adverse inference. The assessment order recorded verification of the later compliance and found it tenable, which indicated that the earlier default had been effectively condoned. On the same facts, the same reasoning was applied to the connected matters, and the penalty under section 272A(1)(d) was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
