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 271B - Determination of turnover of the assessee for Tax Audit u/s 44AB - turnover in respect of the speculative transactions shall be positive and negative differences of the transactions and not volume of the speculative transactions. Accordingly in view of the consist view taken by this Tribunal the turnover of the assessee would not exceed the limit as provide d U/s 44AB, the penalty levied U/s 271B is deleted
Penalty u/s 271B - Determination of turnover of the assessee for Tax Audit u/s 44AB - turnover in respect of the speculative transactions shall be positive and negative differences of the transactions and not volume of the speculative transactions. Accordingly in view of the consist view taken by this Tribunal the turnover of the assessee would not exceed the limit as provide d U/s 44AB, the penalty levied U/s 271B is deleted
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