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...
ITAT upheld CIT(A)'s order, rejecting revenue's penalty claim under section 270A against a charitable trust. The tribunal found no conditions met for penalty imposition, noting the assessee voluntarily filed a revised computation with corrected revenue expenditure. The tribunal determined the excess expenditure claim was within the statutory 15% limit under section 11(1)(a), and the discrepancy did not constitute a deliberate attempt to under-report income. Consequently, the penalty was deleted, and the decision was rendered in favor of the assessee.
ITAT upheld CIT(A)'s order, rejecting revenue's penalty claim under section 270A against a charitable trust. The tribunal found no conditions met for penalty imposition, noting the assessee voluntarily filed a revised computation with corrected revenue expenditure. The tribunal determined the excess expenditure claim was within the statutory 15% limit under section 11(1)(a), and the discrepancy did not constitute a deliberate attempt to under-report income. Consequently, the penalty was deleted, and the decision was rendered in favor of the assessee.
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