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) - 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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