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...
A penalty notice for undisclosed income must specify the precise statutory limb or category of penalty invoked under section 271AAB. The note explains that failure to identify the applicable charge prevents the assessee from addressing the exact allegation and undermines a reasonable opportunity of defence. It states that a notice issued under section 274 read with section 271AAB without this specification is invalid, and that a penalty founded on such defective initiation is liable to be deleted.
A penalty notice for undisclosed income must specify the precise statutory limb or category of penalty invoked under section 271AAB. The note explains that failure to identify the applicable charge prevents the assessee from addressing the exact allegation and undermines a reasonable opportunity of defence. It states that a notice issued under section 274 read with section 271AAB without this specification is invalid, and that a penalty founded on such defective initiation is liable to be deleted.
Note: It is a system-generated summary and is for quick reference only.
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