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 levied u/s 271B - delay in filing the audit report under section 44AB - reasonable cause of delay - The delay was caused due to search conducted by the Department and the books of accounts are not readily available with the assessee. Under the above facts and circumstances, the delay was occurred, in our opinion, the delay in filing the audit report was neither willful nor wanton or inadvertently, it was only beyond the control of the assessee. - AT
Penalty levied u/s 271B - delay in filing the audit report under section 44AB - reasonable cause of delay - The delay was caused due to search conducted by the Department and the books of accounts are not readily available with the assessee. Under the above facts and circumstances, the delay was occurred, in our opinion, the delay in filing the audit report was neither willful nor wanton or inadvertently, it was only beyond the control of the assessee. - AT
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