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...
Deduction of tax at source u/s. 195 - it is proved that assessee is merely a trader of software products of the foreign company - payment made is not in the nature of 'royalty'. - AT
Deduction of tax at source u/s. 195 - it is proved that assessee is merely a trader of software products of the foreign company - payment made is not in the nature of 'royalty'. - AT
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