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) - disallowance of transport expenses - payment made in cash - Just because the payments were made in cash cannot be a basis to doubt the genuineness of the expenditure. Since the disallowance are made on adhoc basis by applying the rate of 15%, holding the assessee liable to pay penalty for furnishing inaccurate particulars of income cannot be held to be justified. - AT
Penalty u/s 271(1)(c) - disallowance of transport expenses - payment made in cash - Just because the payments were made in cash cannot be a basis to doubt the genuineness of the expenditure. Since the disallowance are made on adhoc basis by applying the rate of 15%, holding the assessee liable to pay penalty for furnishing inaccurate particulars of income cannot be held to be justified. - AT
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