Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
TPA - recovery of expenses - it is pure reimbursement of expenses incurred and no service element is involved - AO/TPO is directed to treat the transaction to be at ALP and adjustment to be made at Rs. Nil.
TPA - recovery of expenses - it is pure reimbursement of expenses incurred and no service element is involved - AO/TPO is directed to treat the transaction to be at ALP and adjustment to be made at Rs. Nil.
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