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 271(1)(c) r.w.s. 274 - additional income declared in the return filed in response to notice u/s 153A as compared to original returned filed u/s 139(1) - There was no allegation of concealment or inaccurate particulars of income made by the Ld. AO or Ld. CIT(A) as the additional income was voluntarily disclosed in the return filed u/s 153A without any incriminating material found. - The Tribunal (ITAT) ultimately ruled in favor of the appellant, deleting both penalties levied u/s 271(1)(c).
Penalty proceedings u/s 271(1)(c) r.w.s. 274 - additional income declared in the return filed in response to notice u/s 153A as compared to original returned filed u/s 139(1) - There was no allegation of concealment or inaccurate particulars of income made by the Ld. AO or Ld. CIT(A) as the additional income was voluntarily disclosed in the return filed u/s 153A without any incriminating material found. - The Tribunal (ITAT) ultimately ruled in favor of the appellant, deleting both penalties levied u/s 271(1)(c).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
