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...
Invocation of the extended limitation proviso was examined on whether bona fide belief about Notification No.30/2012 and allocation of tax liability to service recipients supplied a plausible basis for non-payment; the analysis applied authorities requiring fraud, collusion, wilful misstatement or suppression of facts to invoke the extended five-year period. Absent documentary proof of transfer of possession or specific averments proving mala fide conduct or positive acts of suppression, mere non-payment or incomplete returns did not satisfy the threshold, and the extended-period demand was held unsustainable.
Invocation of the extended limitation proviso was examined on whether bona fide belief about Notification No.30/2012 and allocation of tax liability to service recipients supplied a plausible basis for non-payment; the analysis applied authorities requiring fraud, collusion, wilful misstatement or suppression of facts to invoke the extended five-year period. Absent documentary proof of transfer of possession or specific averments proving mala fide conduct or positive acts of suppression, mere non-payment or incomplete returns did not satisfy the threshold, and the extended-period demand was held unsustainable.
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