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...
Valuation of goods - Related person - it is established beyond doubt that the discounts offered are exclusive discounts only to the appellant who is 100% subsidiary of the principal company. Therefore, the appellant's contention that they are eligible for discount of upto 30% for the transfer price is not acceptable - AT
Valuation of goods - Related person - it is established beyond doubt that the discounts offered are exclusive discounts only to the appellant who is 100% subsidiary of the principal company. Therefore, the appellant's contention that they are eligible for discount of upto 30% for the transfer price is not acceptable - AT
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