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...
Non deduction of TDS - Disallowance u/s 40(a)(ia) - payment made on account of offshore supply of equipments - the subject mentioned payments are not chargeable to tax in India in terms of section 195 - Hence, no disallowance could be made u/s. 40(a)(i)/40(a)(ia) - AT
Non deduction of TDS - Disallowance u/s 40(a)(ia) - payment made on account of offshore supply of equipments - the subject mentioned payments are not chargeable to tax in India in terms of section 195 - Hence, no disallowance could be made u/s. 40(a)(i)/40(a)(ia) - AT
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