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...
Consideration / fees for technical services - There is no profit element in the pro rata costs paid by the agents of the assessee to the assessee - the amounts paid by the agents to utilise the amount arose out of the shipping business cannot be brought to tax as sought to be done. - HC
Consideration / fees for technical services - There is no profit element in the pro rata costs paid by the agents of the assessee to the assessee - the amounts paid by the agents to utilise the amount arose out of the shipping business cannot be brought to tax as sought to be done. - HC
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