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...
Accrual of Income in India - Royalty - right to use the software - overriding effect to the DTAA - from reading of the terms of the agreements, it is clear that there was no right to use the computer software - income of the assessee which was brought to tax by the Revenue authorities cannot be brought to tax and the same is directed to be deleted. - AT
Accrual of Income in India - Royalty - right to use the software - overriding effect to the DTAA - from reading of the terms of the agreements, it is clear that there was no right to use the computer software - income of the assessee which was brought to tax by the Revenue authorities cannot be brought to tax and the same is directed to be deleted. - AT
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