Condonation of refiling delay refused where repeated defects, lack of diligence and vague explanations defeated the appeal against resolution plan app...
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TDS u/s 195 - software expenses - the arrangement of the assessee company with its AE is of purchase of computer software at agreed price i.e. sale price to the Indian customers minus margin of the assessee company equal to 15% of cost as specified in letter dated 03.01.2009 although we have seen that actually, it is 15% of the purchase price paid by the assessee company to its AE. - this fact that the assessee company is a distributor does not change the nature of the transaction - AT
TDS u/s 195 - software expenses - the arrangement of the assessee company with its AE is of purchase of computer software at agreed price i.e. sale price to the Indian customers minus margin of the assessee company equal to 15% of cost as specified in letter dated 03.01.2009 although we have seen that actually, it is 15% of the purchase price paid by the assessee company to its AE. - this fact that the assessee company is a distributor does not change the nature of the transaction - AT
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