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 liquidator's determination of security interest and distribution entitlements was treated as tentative, because it was read as flowing from an earlier order already under challenge. The Appellate Tribunal held that the statement could not be read in isolation as a final adjudication overriding the pending appeal, and that the observation on paragraph 45 was not conclusive. As the decision itself showed it was subject to the outcome of the pending appellate proceedings, no party could claim a definitive advantage from it at that stage. The appeal was closed subject to this clarification.
A liquidator's determination of security interest and distribution entitlements was treated as tentative, because it was read as flowing from an earlier order already under challenge. The Appellate Tribunal held that the statement could not be read in isolation as a final adjudication overriding the pending appeal, and that the observation on paragraph 45 was not conclusive. As the decision itself showed it was subject to the outcome of the pending appellate proceedings, no party could claim a definitive advantage from it at that stage. The appeal was closed subject to this clarification.
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