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...
Cash-transaction restrictions under sections 269SS and 271D are discussed in relation to receipts from registered immovable-property sale transactions. The notes state that penalty may not be warranted where cash receipts are from genuine, identifiable parties, are recorded as stock-in-trade, and are supported by registered sale deeds. They describe the restriction's purpose as curbing black-money generation rather than penalising bona fide transactions, and identify proof of genuineness and bona fides as material to relief from penalty.
Cash-transaction restrictions under sections 269SS and 271D are discussed in relation to receipts from registered immovable-property sale transactions. The notes state that penalty may not be warranted where cash receipts are from genuine, identifiable parties, are recorded as stock-in-trade, and are supported by registered sale deeds. They describe the restriction's purpose as curbing black-money generation rather than penalising bona fide transactions, and identify proof of genuineness and bona fides as material to relief from penalty.
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