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...
TP Adjustment - amount disallowed by the AO, viz., Product development expenses, provision for customer claims should be excluded from the cost while computing margin of the assessee - Net margins of the assessee as well as comparable companies are computed under TNM method on the basis of book results without making any adjustment as prescribed in sec.28 to 44 of the Act (both in the hands of the assessee as well as in the hands of comparable companies.) Hence these contentions of the assessee are untenable and hence liable to be rejected. - AT
TP Adjustment - amount disallowed by the AO, viz., Product development expenses, provision for customer claims should be excluded from the cost while computing margin of the assessee - Net margins of the assessee as well as comparable companies are computed under TNM method on the basis of book results without making any adjustment as prescribed in sec.28 to 44 of the Act (both in the hands of the assessee as well as in the hands of comparable companies.) Hence these contentions of the assessee are untenable and hence liable to be rejected. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
