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 High Court considered a case involving non-payment/belated remittance of TDS u/s 276-B of the Income Tax Act. The issue centered on defining "reasonable cause" for the delay in remittance. The Petitioners demonstrated that they promptly remitted the TDS upon receiving fee reimbursements, mostly for students under a government scheme. The Court noted that penalties u/s 271C do not apply for mere belated remittance. Reference was made to Section 201(1A) and Section 276B consequences. Prosecution u/s 276B is subject to Section 278AA, requiring proof of reasonable cause for delay. The Court found the Petitioners' explanation valid, ruling in their favor and negating the need for criminal prosecution.
The High Court considered a case involving non-payment/belated remittance of TDS u/s 276-B of the Income Tax Act. The issue centered on defining "reasonable cause" for the delay in remittance. The Petitioners demonstrated that they promptly remitted the TDS upon receiving fee reimbursements, mostly for students under a government scheme. The Court noted that penalties u/s 271C do not apply for mere belated remittance. Reference was made to Section 201(1A) and Section 276B consequences. Prosecution u/s 276B is subject to Section 278AA, requiring proof of reasonable cause for delay. The Court found the Petitioners' explanation valid, ruling in their favor and negating the need for criminal prosecution.
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