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 270A - The alleged disallowance does not find place in clause (a) to (f) of sub-section (9) of Section 270A. Assessee while filing response to the show cause during the assessment as well as during the penalty proceedings has given bona fide explanation within the scope of sub-section-6 of section 270A and disclosed all the material. - No penalty - AT
Penalty u/s 270A - The alleged disallowance does not find place in clause (a) to (f) of sub-section (9) of Section 270A. Assessee while filing response to the show cause during the assessment as well as during the penalty proceedings has given bona fide explanation within the scope of sub-section-6 of section 270A and disclosed all the material. - No penalty - AT
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