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...
Disallowance under section 40(a)(ia) - secondment of employees to the assessee in India - such reimbursement of expenses are not income in the hands of the non-resident and therefore, TDS provisions are not applicable. - AT
Disallowance under section 40(a)(ia) - secondment of employees to the assessee in India - such reimbursement of expenses are not income in the hands of the non-resident and therefore, TDS provisions are not applicable. - AT
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