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...
Levy of penalty u/s 271B - no initiation of penalty u/s 271B despite higher gross receipt was available to the AO while passing the original assessment order - penalty proceedings initiated in order passed in remanded matter by Tribunal after a long gap of more than 4 ½ years from the date of original assessment is barred by limitation
Levy of penalty u/s 271B - no initiation of penalty u/s 271B despite higher gross receipt was available to the AO while passing the original assessment order - penalty proceedings initiated in order passed in remanded matter by Tribunal after a long gap of more than 4 ½ years from the date of original assessment is barred by limitation
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