Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
TP Adjustment - payment made to its AE towards Maintenance services relating to software licenses - There is merit in the contentions of the assessee that the distribution of software licenses and their maintenance are inter-linked. - TPO was not justified in viewing maintenance services as separate from the distribution activity.
TP Adjustment - payment made to its AE towards Maintenance services relating to software licenses - There is merit in the contentions of the assessee that the distribution of software licenses and their maintenance are inter-linked. - TPO was not justified in viewing maintenance services as separate from the distribution activity.
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