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...
Transfer Pricing adjustment - The assessee could not have approached the two unrelated parties and have asked them to explain why they were giving discount to the assessee. The upward adjustments made by the TPO are uncalled for - AT
Transfer Pricing adjustment - The assessee could not have approached the two unrelated parties and have asked them to explain why they were giving discount to the assessee. The upward adjustments made by the TPO are uncalled for - AT
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