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 notices must specify whether the alleged default is concealment of income or furnishing inaccurate particulars; retaining both alternatives without identifying the charge indicates non-application of mind and may deny an adequate opportunity to respond. The notes also address penalties for delayed employees' provident fund contributions and book-profit adjustments, stating that a debatable disallowance or mere rejection of a claim does not itself establish concealment, inaccurate particulars, or wilful tax evasion. An excess weighted research deduction claimed on disclosed material before subsequent approval may be bona fide. Penalty for under-reporting also requires identification and communication of the applicable statutory circumstance, failing which proceedings breach natural justice.
Penalty notices must specify whether the alleged default is concealment of income or furnishing inaccurate particulars; retaining both alternatives without identifying the charge indicates non-application of mind and may deny an adequate opportunity to respond. The notes also address penalties for delayed employees' provident fund contributions and book-profit adjustments, stating that a debatable disallowance or mere rejection of a claim does not itself establish concealment, inaccurate particulars, or wilful tax evasion. An excess weighted research deduction claimed on disclosed material before subsequent approval may be bona fide. Penalty for under-reporting also requires identification and communication of the applicable statutory circumstance, failing which proceedings breach natural justice.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
