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...
Invocation of extended period of limitation - Willful suppression of facts - Works contact - lump sum turnkey contract - this is a clear cut case of wilful statement as also suppression of facts. Submissions of some letters/contracts in the facts of this case will not make any difference - AT
Invocation of extended period of limitation - Willful suppression of facts - Works contact - lump sum turnkey contract - this is a clear cut case of wilful statement as also suppression of facts. Submissions of some letters/contracts in the facts of this case will not make any difference - AT
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