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 271D & 271E - Contravention of provisions of Section 269SS & 269TT - Accepting and repayment of loans / deposits in Cash from the Managing Director of the Assessee Company - The justification given by the assessee for receiving loans in cash is unsubstantiated, as they received and repaid huge amounts without reasonable cause. Therefore, the penalty is justified. - AT
Penalty u/s 271D & 271E - Contravention of provisions of Section 269SS & 269TT - Accepting and repayment of loans / deposits in Cash from the Managing Director of the Assessee Company - The justification given by the assessee for receiving loans in cash is unsubstantiated, as they received and repaid huge amounts without reasonable cause. Therefore, the penalty is justified. - AT
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