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 Sections 112(a) and 112(b) could not be sustained because the show-cause notice did not propose those penalties; the Tribunal set them aside for want of notice. Section 114AA was held to cover any knowing or intentional use of a false or incorrect declaration, statement or document in transactions under the Act, including import matters; the Tribunal therefore confirmed the penalty under that provision.
Penalty under Sections 112(a) and 112(b) could not be sustained because the show-cause notice did not propose those penalties; the Tribunal set them aside for want of notice. Section 114AA was held to cover any knowing or intentional use of a false or incorrect declaration, statement or document in transactions under the Act, including import matters; the Tribunal therefore confirmed the penalty under that provision.
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