Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Review petition - Levy of penalty u/s 271(1)(c) - Tribunal sustaining the levy without providing an opportunity of hearing - Review applicant had paid entire tax amount for assessment years in question - Held that review applicant has not filed applications based on new facts - Materials collected during search never put to review applicant prior to filing voluntary revised returns - No deliberate or wilful omission on part of review applicant - Review applicant on same footing as Dr. R. Gopalakrishnan entitled to same relief - Plea of review applicant being professional doctor rendering service to downtrodden people and levying penalty would affect mental status and professional career appears bona fide and reasonable, merits acceptance - Judgment recalled, Tax Case Appeals disposed of by setting aside order.
Review petition - Levy of penalty u/s 271(1)(c) - Tribunal sustaining the levy without providing an opportunity of hearing - Review applicant had paid entire tax amount for assessment years in question - Held that review applicant has not filed applications based on new facts - Materials collected during search never put to review applicant prior to filing voluntary revised returns - No deliberate or wilful omission on part of review applicant - Review applicant on same footing as Dr. R. Gopalakrishnan entitled to same relief - Plea of review applicant being professional doctor rendering service to downtrodden people and levying penalty would affect mental status and professional career appears bona fide and reasonable, merits acceptance - Judgment recalled, Tax Case Appeals disposed of by setting aside order.
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