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...
The Commissioner had limited scope in the remand proceedings and could not have put the appellants in more precarious position then what was held against them in the earlier proceedings specifically when revenue had not filed any appeal against the earlier order.
The Commissioner had limited scope in the remand proceedings and could not have put the appellants in more precarious position then what was held against them in the earlier proceedings specifically when revenue had not filed any appeal against the earlier order.
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