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...
Refund claim - Period of limitation - claim was filed on 29.07.2004 which was returned on the ground of pre-mature inasmuch as investigation about the valuation work was still going on, accordingly, appellant resubmitted their claim on 28.10.2005 - refund allowed - Provision of unjust enrichment not applicable where the amount is deposited during the investigation - AT
Refund claim - Period of limitation - claim was filed on 29.07.2004 which was returned on the ground of pre-mature inasmuch as investigation about the valuation work was still going on, accordingly, appellant resubmitted their claim on 28.10.2005 - refund allowed - Provision of unjust enrichment not applicable where the amount is deposited during the investigation - AT
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