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...
Audited financial statements were treated as the reliable basis for determining closing work-in-progress where unaudited tally-generated data showed a difference caused by adding, rather than excluding, opening work-in-progress. As the audited accounts correctly reflected the brought-forward opening balance and the relevant year's closing work-in-progress, no discrepancy remained to support an addition based solely on unaudited data. The discussion states that the addition for the alleged difference in closing work-in-progress, as well as the stock-in-trade difference, was deleted.
Audited financial statements were treated as the reliable basis for determining closing work-in-progress where unaudited tally-generated data showed a difference caused by adding, rather than excluding, opening work-in-progress. As the audited accounts correctly reflected the brought-forward opening balance and the relevant year's closing work-in-progress, no discrepancy remained to support an addition based solely on unaudited data. The discussion states that the addition for the alleged difference in closing work-in-progress, as well as the stock-in-trade difference, was deleted.
Note: It is a system-generated summary and is for quick reference only.
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