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...
Higher rate of TDS @20% for non-furnishing of PAN u/s 206AA - whether cannot be at a rate prescribed u/s 206AA which is higher than the rate at which the relevant income is chargeable to tax under Act or DTAA - the scope of deduction of tax at source cannot be more than the tax liability under DTAA. - AT
Higher rate of TDS @20% for non-furnishing of PAN u/s 206AA - whether cannot be at a rate prescribed u/s 206AA which is higher than the rate at which the relevant income is chargeable to tax under Act or DTAA - the scope of deduction of tax at source cannot be more than the tax liability under DTAA. - AT
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