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...
Export of services - sale promotion and back office accounting services - the benefits of the services provided by the appellant has accrued to the foreign principals - consideration was received in convertible foreign currency - benefit of export allowed - AT
Export of services - sale promotion and back office accounting services - the benefits of the services provided by the appellant has accrued to the foreign principals - consideration was received in convertible foreign currency - benefit of export allowed - AT
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