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...
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Compounding of offence(s) - determination of compounding fee - first occasion - 5% or 3% of the amount of tax in default - Since a common application had been filed for the aforementioned FYs for the first time, it would fall within the expression “first occasion”, as indicated in the guidelines for compounding of offences under Direct Tax Laws, 2019. - the compounding fee should have been calculated at the rate of 3%, and not at 5% - HC
Compounding of offence(s) - determination of compounding fee - first occasion - 5% or 3% of the amount of tax in default - Since a common application had been filed for the aforementioned FYs for the first time, it would fall within the expression “first occasion”, as indicated in the guidelines for compounding of offences under Direct Tax Laws, 2019. - the compounding fee should have been calculated at the rate of 3%, and not at 5% - HC
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