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...
Once a return is filed and accepted under Section 153A, the earlier return under Section 139(1) is treated as non est for judging disclosure, so penalty under Section 271(1)(c) cannot be levied merely because the 153A return shows higher income. The ITAT also held that, in an unabated assessment, additions and penalty could not be sustained absent incriminating material found during search in relation to the voluntarily offered amounts. Relying on the principles in Neeraj Jindal and Abhisar Buildwell, the penalties for the relevant assessment years were deleted.
Once a return is filed and accepted under Section 153A, the earlier return under Section 139(1) is treated as non est for judging disclosure, so penalty under Section 271(1)(c) cannot be levied merely because the 153A return shows higher income. The ITAT also held that, in an unabated assessment, additions and penalty could not be sustained absent incriminating material found during search in relation to the voluntarily offered amounts. Relying on the principles in Neeraj Jindal and Abhisar Buildwell, the penalties for the relevant assessment years were deleted.
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