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 proceedings u/s 271D, 271E and 271AAA - period of limitation - the period of six months from the end of the month in which action for imposition of penalty was initiated ended on 30.06.2011. - Concededly, the penalty order was passed way beyond the later date i.e., 30.06.2011. The record discloses that the penalty order was passed on 30.12.2011. - No penalty - HC
Penalty proceedings u/s 271D, 271E and 271AAA - period of limitation - the period of six months from the end of the month in which action for imposition of penalty was initiated ended on 30.06.2011. - Concededly, the penalty order was passed way beyond the later date i.e., 30.06.2011. The record discloses that the penalty order was passed on 30.12.2011. - No penalty - HC
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