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...
Rejection of refund claim – admittedly price has been administered by APM regime and selling price has been fixed by Government - bar of unjust enrichment is not applicable to facts of these appeals - refund allowed - AT
Rejection of refund claim – admittedly price has been administered by APM regime and selling price has been fixed by Government - bar of unjust enrichment is not applicable to facts of these appeals - refund allowed - AT
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