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 u/s 271(1)(c) - Penalty will not merely be imposed because it was lawful to do so - once the explanation was not held to be false, the penalty cannot be sustained - AT
Penalty u/s 271(1)(c) - Penalty will not merely be imposed because it was lawful to do so - once the explanation was not held to be false, the penalty cannot be sustained - AT
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