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...
The ITAT Ahmedabad, in proceedings u/s 201(1) and 201(1A), found the assessee-in-default for non-deduction of TDS u/s 194IA on property purchases. The assessee failed to provide evidence to support eligibility for proviso to Section 201(1), leading to dismissal of appeal. Interest u/s 201(1A) upheld till payee's return filing. Penalty u/s 271(c) for non-deduction of TDS u/s 194-IA was deemed justified. The appeal was decided against the assessee.
The ITAT Ahmedabad, in proceedings u/s 201(1) and 201(1A), found the assessee-in-default for non-deduction of TDS u/s 194IA on property purchases. The assessee failed to provide evidence to support eligibility for proviso to Section 201(1), leading to dismissal of appeal. Interest u/s 201(1A) upheld till payee's return filing. Penalty u/s 271(c) for non-deduction of TDS u/s 194-IA was deemed justified. The appeal was decided against the assessee.
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