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...
HC considered a case involving offences u/s 276 C (2) r/w sec 278 B of Criminal Procedure for Economic Offences. Petitioners filed returns without paying tax, attributing it to auditors' mistake. They paid the tax upon realization. Citing M/s. Bejan Singh Eye Hospital Pvt. Ltd, HC held a positive act is needed to establish guilt u/s 276 C (2). Since petitioners paid tax with interest upon notice, showing no intent to evade tax, proceedings were quashed. Criminal Petition allowed, proceedings against petitioners quashed by HC.
HC considered a case involving offences u/s 276 C (2) r/w sec 278 B of Criminal Procedure for Economic Offences. Petitioners filed returns without paying tax, attributing it to auditors' mistake. They paid the tax upon realization. Citing M/s. Bejan Singh Eye Hospital Pvt. Ltd, HC held a positive act is needed to establish guilt u/s 276 C (2). Since petitioners paid tax with interest upon notice, showing no intent to evade tax, proceedings were quashed. Criminal Petition allowed, proceedings against petitioners quashed by HC.
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