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 - Business Auxiliary Services or not - Sales Promotion Agency - Although there is only one wholesale buyer, APBCL, their orders depend on the orders which the retailers place on the depots of APBCL. The appellant was specifically required to ensure that the retailers place maximum quantities of the client’s products on APBCL depots. Thus, the services rendered by the appellant are in the nature of promotion and marketing of the clients’ products - AT
Classification of services - Business Auxiliary Services or not - Sales Promotion Agency - Although there is only one wholesale buyer, APBCL, their orders depend on the orders which the retailers place on the depots of APBCL. The appellant was specifically required to ensure that the retailers place maximum quantities of the client’s products on APBCL depots. Thus, the services rendered by the appellant are in the nature of promotion and marketing of the clients’ products - AT
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