Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Penalty u/s 271 (1) (c) - adoption of multiple year data OR single year data for determining ALP - the fact remains that the legislature thought it necessary to clarify that the data that was required to be used had to necessarily relate to the financial year in question and not to multiple year data - during the AY in question, the issue was debatable - no penalty
Penalty u/s 271 (1) (c) - adoption of multiple year data OR single year data for determining ALP - the fact remains that the legislature thought it necessary to clarify that the data that was required to be used had to necessarily relate to the financial year in question and not to multiple year data - during the AY in question, the issue was debatable - no penalty
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