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...
Refund of accumulated credit - ascertainment of eligible refund under Rule 5 - In both the numerator and denominator, the amount of export turnover have to be considered (i.e. same figure ) when there is no domestic services rendered by the assessee appellant inasmuch as the “value of all other services” would be ‘NIL’ in the given case. There is no reason to consider the aggregate of the value of export turnover payment of which has been received and those for which payment has not been received, since not required in the prescribed formula - AT
Refund of accumulated credit - ascertainment of eligible refund under Rule 5 - In both the numerator and denominator, the amount of export turnover have to be considered (i.e. same figure ) when there is no domestic services rendered by the assessee appellant inasmuch as the “value of all other services” would be ‘NIL’ in the given case. There is no reason to consider the aggregate of the value of export turnover payment of which has been received and those for which payment has not been received, since not required in the prescribed formula - AT
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