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 - ALP of the royalty paid AE - royalty paid by other group entities are controlled transactions whereas, rule 10B(1)(a) mandates that the price charged for an uncontrolled transaction/transaction should be considered as a CUP - the determination of arm's length price as approved by the RBI/SIA is valid
TP Adjustment - ALP of the royalty paid AE - royalty paid by other group entities are controlled transactions whereas, rule 10B(1)(a) mandates that the price charged for an uncontrolled transaction/transaction should be considered as a CUP - the determination of arm's length price as approved by the RBI/SIA is valid
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