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...
Classification - - vehicle was hired out to third person for the purpose of his journey - There was no tour actually conducted by the appellant in the present case. Neither the appellant adduced evidence in that regard nor also any of the circumstantial evidence could demonstrate in its favour to treat the appellant as a tour operator. - appellant’s claim fails on the plea of classification as tour operator - AT
Classification - - vehicle was hired out to third person for the purpose of his journey - There was no tour actually conducted by the appellant in the present case. Neither the appellant adduced evidence in that regard nor also any of the circumstantial evidence could demonstrate in its favour to treat the appellant as a tour operator. - appellant’s claim fails on the plea of classification as tour operator - AT
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