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...
Classification of services - IPR service or franchise service? - manufacture and sale of various formulations (fast moving consumer goods) - The arrangement is clearly a typical case of a licensing transaction and is in no way similar to a ‘franchisee’ agreement as understood in the commercial world. - When the services received by the Appellant would merit classification under IPR service, the Appellant would also be entitled to abatement of Service Tax available to a holder of IPR
Classification of services - IPR service or franchise service? - manufacture and sale of various formulations (fast moving consumer goods) - The arrangement is clearly a typical case of a licensing transaction and is in no way similar to a ‘franchisee’ agreement as understood in the commercial world. - When the services received by the Appellant would merit classification under IPR service, the Appellant would also be entitled to abatement of Service Tax available to a holder of IPR
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