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 - reimbursable expenses - It would not be possible to draw a distinction between the portion of the consideration that does not relate to these activities. In consequence, the tax liability crystallises on the gross value services subject to the various deductions permitted by the first appellate authority - demand with interest upheld.
Valuation - reimbursable expenses - It would not be possible to draw a distinction between the portion of the consideration that does not relate to these activities. In consequence, the tax liability crystallises on the gross value services subject to the various deductions permitted by the first appellate authority - demand with interest upheld.
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