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...
Justification for the expenditure - amount paid towards secondment of employees - The contention of the AO that, real beneficiary of the Australian entity’s employees was not the JV but the AE, rejected. - Revenue is not permitted to hold salary payment reimbursed to AE is a non deductible expenditure.
Justification for the expenditure - amount paid towards secondment of employees - The contention of the AO that, real beneficiary of the Australian entity’s employees was not the JV but the AE, rejected. - Revenue is not permitted to hold salary payment reimbursed to AE is a non deductible expenditure.
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