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...
A statement recorded under section 108 could not sustain penalty because the mandatory procedure under section 138B was not followed, rendering the statement inadmissible for evidentiary reliance. Penalty under section 112(b) also failed because the statutory ingredients were not proved: there was no established dealing with goods liable to confiscation and no of knowledge or reason to believe that the goods were so liable. On these findings, the Tribunal set aside the penalty and allowed the appeal.
A statement recorded under section 108 could not sustain penalty because the mandatory procedure under section 138B was not followed, rendering the statement inadmissible for evidentiary reliance. Penalty under section 112(b) also failed because the statutory ingredients were not proved: there was no established dealing with goods liable to confiscation and no of knowledge or reason to believe that the goods were so liable. On these findings, the Tribunal set aside the penalty and allowed the appeal.
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