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Showing contexts for: Software Source code in Red Hat India P.Ltd, Mumbai vs Dcit Circle 15(3)(1), Mumbai on 29 June, 2021Matching Fragments
2.10 The Ld. AO erred on facts and in law in initiating penalty proceedings under section 274 read with section 271(l)(c) of the Act.
The Appellant craves leave to add to, or alter, by deletion, substitution, modification or otherwise, the above grounds of appeal, either before or during the hearing of the appeal.
3. Brief facts and the assessee's main grievances are summarized in the following submission by assessee.
1.1. Business profile • Red Hat US is a provider of open-source solutions for internet computing; • An open source software typically grants every user free access to the source code and enable the customers to modify and customize the software to suit their requirements, unlike a proprietary software where source codes are owned by developers; # • Once an open source software is downloaded, software users may require access to ongoing support services;