Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Penalty u/s 271(1)(c) - the onus lies on the assessee to establish that the addition sustaied by Mutual Agreement Procedure(MAP) under DTAA with India and other sovereign countries is not due to concealment of income or furnishing of inaccurate particulars and the computation was made u/s 92C in the manner prescribed under that Section, in good faith and with due diligence - penalty provision relating to this is not ultra virus
Penalty u/s 271(1)(c) - the onus lies on the assessee to establish that the addition sustaied by Mutual Agreement Procedure(MAP) under DTAA with India and other sovereign countries is not due to concealment of income or furnishing of inaccurate particulars and the computation was made u/s 92C in the manner prescribed under that Section, in good faith and with due diligence - penalty provision relating to this is not ultra virus
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