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...
Characterization of income - interest earned on ICDs - assessee is not in money lending business - when it is accepted that the assessee has taken a prudent business decision to earn some income by utilizing the idle business funds, no differentiation can be made between the investments made in banks and ICDs - the interest income earned on ICDs should be treated as income from business
Characterization of income - interest earned on ICDs - assessee is not in money lending business - when it is accepted that the assessee has taken a prudent business decision to earn some income by utilizing the idle business funds, no differentiation can be made between the investments made in banks and ICDs - the interest income earned on ICDs should be treated as income from business
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