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) - payments ‘made to any concern in which the shareholder is a member’ - common shareholder having a substantial interest in the assessee company as well as in the creditor companies - Revenue failed to prove that the case is falling under the second limb of section 2(22)(e).
Deemed dividend u/s 2(22)(e) - payments ‘made to any concern in which the shareholder is a member’ - common shareholder having a substantial interest in the assessee company as well as in the creditor companies - Revenue failed to prove that the case is falling under the second limb of section 2(22)(e).
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