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...
Section 194Q compliance assessments must address Circular No. 13/2021, which provides guidelines for removing difficulties in applying tax deduction requirements to business purchases. A determination concerning alleged non-deduction that does not examine the circular's relevance cannot be sustained. The assessment must therefore be set aside and reconsidered by the assessing authority in light of the circular and applicable law.
Section 194Q compliance assessments must address Circular No. 13/2021, which provides guidelines for removing difficulties in applying tax deduction requirements to business purchases. A determination concerning alleged non-deduction that does not examine the circular's relevance cannot be sustained. The assessment must therefore be set aside and reconsidered by the assessing authority in light of the circular and applicable law.
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