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...
When the appellant did not avail opportunity to reconcile the figures and guide the authorities below as to which figure shall govern the appellant, there is no necessity to remand the matter for further opportunity. - AT
When the appellant did not avail opportunity to reconcile the figures and guide the authorities below as to which figure shall govern the appellant, there is no necessity to remand the matter for further opportunity. - AT
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