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. 271E - period of limitation - There is no dispute that the period of limitation is required to be examined as per Section 275(1)(c) - it is futile to contend that the date of initiation of proceedings is the date on which the JCIT receives intimation from the AO or the date on which the JCIT issues SCN to the Assessee - AO having initiated the penalty proceedings in assessment order dated 24.3.2016 and imposed on 27.1.2017 - bared by limitation
Penalty u/s. 271E - period of limitation - There is no dispute that the period of limitation is required to be examined as per Section 275(1)(c) - it is futile to contend that the date of initiation of proceedings is the date on which the JCIT receives intimation from the AO or the date on which the JCIT issues SCN to the Assessee - AO having initiated the penalty proceedings in assessment order dated 24.3.2016 and imposed on 27.1.2017 - bared by limitation
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