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...
Penalty under section 271D for alleged section 269SS violation was held time-barred where the Assessing Officer had recorded satisfaction and referred the matter for penalty during assessment, because limitation under section 275(1)(c) ran from the end of that month and was not extended by the later penalty notice. The penalty was also found unsustainable on merits: the receipt was genuine sale consideration for agricultural land, the assessee showed reasonable cause under section 273B, and the bona fide belief that such a transaction would not attract section 269SS negatived penalty. The levy was therefore quashed.
Penalty under section 271D for alleged section 269SS violation was held time-barred where the Assessing Officer had recorded satisfaction and referred the matter for penalty during assessment, because limitation under section 275(1)(c) ran from the end of that month and was not extended by the later penalty notice. The penalty was also found unsustainable on merits: the receipt was genuine sale consideration for agricultural land, the assessee showed reasonable cause under section 273B, and the bona fide belief that such a transaction would not attract section 269SS negatived penalty. The levy was therefore quashed.
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