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) - Though the addition is confirmed by the CIT(A), but does not show that the assessee has not recorded any transaction in his books of account or any transaction recorded by him is false - Addition on account of gross profit was purely on estimation basis - No penalty
Penalty u/s 271(1)(c) - Though the addition is confirmed by the CIT(A), but does not show that the assessee has not recorded any transaction in his books of account or any transaction recorded by him is false - Addition on account of gross profit was purely on estimation basis - No penalty
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