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) - concealment or furnishing inaccurate particulars - Where the explanation is not make belief and sham but genuine, the assessee would satisfy the requirement of Explanation 1 to Section 271(1)(c). This test and requirement is satisfied in the present case.
Penalty u/s 271(1)(c) - concealment or furnishing inaccurate particulars - Where the explanation is not make belief and sham but genuine, the assessee would satisfy the requirement of Explanation 1 to Section 271(1)(c). This test and requirement is satisfied in the present case.
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