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...
Carry forward and set-off of losses - demerger - Applicability of provisions of Sec. 72A(4) - transfer of only the specified assets and liabilities - the scheme of arrangement in question does not qualify to be a ‘demerger’ in terms of section 2(19AA) - AT
Carry forward and set-off of losses - demerger - Applicability of provisions of Sec. 72A(4) - transfer of only the specified assets and liabilities - the scheme of arrangement in question does not qualify to be a ‘demerger’ in terms of section 2(19AA) - AT
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