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...
Disallowance on account of commission paid to 5 persons - Contention of the assessee that since out of the 5 ladies, 2 have confirmed the transactions, therefore by preponderance of probabilities it can be safely presumed that the transactions with other 3 ladies were also genuine is not acceptable. - AT
Disallowance on account of commission paid to 5 persons - Contention of the assessee that since out of the 5 ladies, 2 have confirmed the transactions, therefore by preponderance of probabilities it can be safely presumed that the transactions with other 3 ladies were also genuine is not acceptable. - AT
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