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...
Extended period of limitation - period 9.7.2004 to 6.11.2005 - Board clarified vide its Circular on 17.10.2005 that software is 'goods', the show-cause notice in the present case was issued only on 2.1.2007 i.e. beyond the normal period of one year - demand set aside - AT
Extended period of limitation - period 9.7.2004 to 6.11.2005 - Board clarified vide its Circular on 17.10.2005 that software is 'goods', the show-cause notice in the present case was issued only on 2.1.2007 i.e. beyond the normal period of one year - demand set aside - AT
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