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...
Recording of wrong facts & reasoning by Tribunal - Tribunal did not correctly appreciate as to what AO and CIT (A) held and what was their reasoning which led to their respective conclusion - Tribunal being the last Court of appeal on facts, its finding on the question of fact is of significance - case remanded to tribunal
Recording of wrong facts & reasoning by Tribunal - Tribunal did not correctly appreciate as to what AO and CIT (A) held and what was their reasoning which led to their respective conclusion - Tribunal being the last Court of appeal on facts, its finding on the question of fact is of significance - case remanded to tribunal
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