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...
Assessment u/s 153A - Addition for the pay-in from NBOT - AO was not justified as he cannot pick and choose the figures at his/her pleasure. Once it was decided to make the addition on the basis of gross transactions with NBOT then Ld. Assessing Officer was bound to consider both the figures of pay-in and pay-out. - AT
Assessment u/s 153A - Addition for the pay-in from NBOT - AO was not justified as he cannot pick and choose the figures at his/her pleasure. Once it was decided to make the addition on the basis of gross transactions with NBOT then Ld. Assessing Officer was bound to consider both the figures of pay-in and pay-out. - AT
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