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 belated filing of TDS returns may not be sustained where penalty proceedings are initiated after an unexplained nine-year lapse. The Tribunal note states that, following a coordinate Bench decision on materially similar facts, the delayed penalty was treated as illegal and unsustainable. The penalty order was set aside and the taxpayer's appeal was allowed.
Penalty for belated filing of TDS returns may not be sustained where penalty proceedings are initiated after an unexplained nine-year lapse. The Tribunal note states that, following a coordinate Bench decision on materially similar facts, the delayed penalty was treated as illegal and unsustainable. The penalty order was set aside and the taxpayer's appeal was allowed.
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