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 for non-compliance with statutory notices under section 271(1)(b) is not sustainable where the assessee establishes reasonable cause under section 273B. The Tribunal accepted that the assessee was not a regular taxpayer, was unaware of the income-tax proceedings and portal-related compliance, and learnt of the ex parte assessment only after demand was raised. It also noted that the quantum matter had already been restored to the AO. On these facts, the defaults in responding to the notices were treated as sufficiently explained, and the penalty was deleted.
Penalty for non-compliance with statutory notices under section 271(1)(b) is not sustainable where the assessee establishes reasonable cause under section 273B. The Tribunal accepted that the assessee was not a regular taxpayer, was unaware of the income-tax proceedings and portal-related compliance, and learnt of the ex parte assessment only after demand was raised. It also noted that the quantum matter had already been restored to the AO. On these facts, the defaults in responding to the notices were treated as sufficiently explained, and the penalty was deleted.
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