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 - Delay in filing the tax audit report - delay occurred due to the Accountant leaving the job abruptly and it took time for the new Accountant to finalize the accounts - For other years, the assessee was regular in filing the TAR - this is the only year where there is a delay in getting the books of accounts audited u/s 44AB - In the case on hand the tax audit report was filed on 08.03.2018, the return was field on 09.03.2018 and the assessment was completed on 30.12.2019 on which date the tax audit report was very much before the Assessing Officer. Further the assessment was completed accepting the loss returned by the assessee. - No penalty - AT
Penalty u/s 271B - Delay in filing the tax audit report - delay occurred due to the Accountant leaving the job abruptly and it took time for the new Accountant to finalize the accounts - For other years, the assessee was regular in filing the TAR - this is the only year where there is a delay in getting the books of accounts audited u/s 44AB - In the case on hand the tax audit report was filed on 08.03.2018, the return was field on 09.03.2018 and the assessment was completed on 30.12.2019 on which date the tax audit report was very much before the Assessing Officer. Further the assessment was completed accepting the loss returned by the assessee. - No penalty - AT
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