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. 271AAA(2) - Assessment u/s 153 - where the revenue had failed to question the assessee while recording the statement u/s 132(4) of the Act as regards the manner of deriving such income, it cannot jump to the consequential or laster requirement of substantiating the manner of deriving the income.
Penalty u/s. 271AAA(2) - Assessment u/s 153 - where the revenue had failed to question the assessee while recording the statement u/s 132(4) of the Act as regards the manner of deriving such income, it cannot jump to the consequential or laster requirement of substantiating the manner of deriving the income.
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