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...
Disallowance of depreciation rejecting concept of 'Block of Asset' - use of individual assets - business use of each item of a block of assets is not necessary for allowing depreciation on the block
Disallowance of depreciation rejecting concept of 'Block of Asset' - use of individual assets - business use of each item of a block of assets is not necessary for allowing depreciation on the block
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