Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Transfer pricing adjustment - Correspondent Banking Activities - The main business transactions have been accepted to be at arm’s length and hence, the ld. TPO cannot separately treat the incidental benefit as a separate transaction unless it is shown that they are separate from the main business activities. - No transfer pricing adjustment on account of correspondent banking activity is warranted in the instant case
Transfer pricing adjustment - Correspondent Banking Activities - The main business transactions have been accepted to be at arm’s length and hence, the ld. TPO cannot separately treat the incidental benefit as a separate transaction unless it is shown that they are separate from the main business activities. - No transfer pricing adjustment on account of correspondent banking activity is warranted in the instant case
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