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...
Where an addition in assessment arose solely from an estimation of non-genuine purchases and the taxable profit element was computed on that estimate, the statutory threshold for levying a penalty for concealment or furnishing inaccurate particulars was not met. Precedents establish that estimate-based disallowances, made without concrete evidence of deliberate concealment, do not attract penalty liability. Applying that principle, the tribunal directed deletion of the penalty levied in respect of the assessment year because the impugned addition was founded on estimate and therefore did not justify a penalty.
Where an addition in assessment arose solely from an estimation of non-genuine purchases and the taxable profit element was computed on that estimate, the statutory threshold for levying a penalty for concealment or furnishing inaccurate particulars was not met. Precedents establish that estimate-based disallowances, made without concrete evidence of deliberate concealment, do not attract penalty liability. Applying that principle, the tribunal directed deletion of the penalty levied in respect of the assessment year because the impugned addition was founded on estimate and therefore did not justify a penalty.
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