Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Page of 4811
Press 'Enter' after typing page number.
3801 to 3820 of 96208 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
On materially identical facts, the adjustment for PTSE services, IT support services and centralized support services was unsustainable because the assessee had already shown rendition of services through agreements, invoices, emails, cost allocation workings and third-party evidence, and the earlier co-ordinate Bench had rejected a nil arm's length price. No distinguishing feature was shown for the year under consideration, so the binding earlier decision had to be followed. Mere pendency of the revenue's appeal did not dilute that precedent absent any stay or reversal. The transfer pricing adjustment was therefore deleted and the appeal allowed.
On materially identical facts, the adjustment for PTSE services, IT support services and centralized support services was unsustainable because the assessee had already shown rendition of services through agreements, invoices, emails, cost allocation workings and third-party evidence, and the earlier co-ordinate Bench had rejected a nil arm's length price. No distinguishing feature was shown for the year under consideration, so the binding earlier decision had to be followed. Mere pendency of the revenue's appeal did not dilute that precedent absent any stay or reversal. The transfer pricing adjustment was therefore deleted and the appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
