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...
Deemed dividend u/s 2(22)(e) - assessee claimed the amount received as guarantee fee for advance received from Ginza - the real intent of Ginza in advancing the sums it did to the assessee was to share its profit by way of deemed dividend - Decided in favor of revenue - HC
Deemed dividend u/s 2(22)(e) - assessee claimed the amount received as guarantee fee for advance received from Ginza - the real intent of Ginza in advancing the sums it did to the assessee was to share its profit by way of deemed dividend - Decided in favor of revenue - HC
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