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...
TP Adjustment - share application money remained parked with AE - nothing on record to prove that transaction was sham - TPO could not have treated such transaction as a loan and charged interest thereon on notional basis.
TP Adjustment - share application money remained parked with AE - nothing on record to prove that transaction was sham - TPO could not have treated such transaction as a loan and charged interest thereon on notional basis.
Note: It is a system-generated summary and is for quick reference only.