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 - transaction value was enhanced on the basis of certain alleged emails of third party - under-valuation must be established through proper methods under the law and that burden cannot be shifted to the importer - AT
Valuation - transaction value was enhanced on the basis of certain alleged emails of third party - under-valuation must be established through proper methods under the law and that burden cannot be shifted to the importer - AT
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