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...
Rectification u/s 254(2) - failure to take cognizance of certain judicial pronouncements - non-consideration of the judgments of the jurisdictional High Court and the Tribunal, which were specifically relied upon by the counsel during the course of the hearing of the appeal constitutes a mistake apparent from record - rectification allowable
Rectification u/s 254(2) - failure to take cognizance of certain judicial pronouncements - non-consideration of the judgments of the jurisdictional High Court and the Tribunal, which were specifically relied upon by the counsel during the course of the hearing of the appeal constitutes a mistake apparent from record - rectification allowable
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