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 - exclusion and inclusion of comparables - since in respect of each of the comparables, the ITAT has given detailed reasons why the comparables should be rejected either because of failing the filter or because of functional dissimilarity and also followed earlier decisions concerning assessee - no substantial question of law arises
TP adjustment - exclusion and inclusion of comparables - since in respect of each of the comparables, the ITAT has given detailed reasons why the comparables should be rejected either because of failing the filter or because of functional dissimilarity and also followed earlier decisions concerning assessee - no substantial question of law arises
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