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...
Extended period limitation - ST liability on payment to overseas Sales Commission Agent under RCM - being CENVAT was available,it is Revenue neutral situation - it cannot be said that there was malafide intention on the part of the appellant in non-payment of service tax - extended period was clearly not invokable
Extended period limitation - ST liability on payment to overseas Sales Commission Agent under RCM - being CENVAT was available,it is Revenue neutral situation - it cannot be said that there was malafide intention on the part of the appellant in non-payment of service tax - extended period was clearly not invokable
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