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 271G - non–maintenance of documents which the assessee is required to maintain under the statutory provisions, the Transfer Pricing Officer found it difficult to determine, the arm’s length price of the transactions with the AE - The blame for failure on the part of the TPO to determine the arm’s length price cannot be fastened with the assessee - No penalty - AT
Penalty u/s 271G - non–maintenance of documents which the assessee is required to maintain under the statutory provisions, the Transfer Pricing Officer found it difficult to determine, the arm’s length price of the transactions with the AE - The blame for failure on the part of the TPO to determine the arm’s length price cannot be fastened with the assessee - No penalty - AT
Note: It is a system-generated summary and is for quick reference only.