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...
Valuation of Vessel - Whether the transaction value of the vessel is to be priced mentioned in the original MOA or the reduced price indicated in the addendum? - the genuineness and the necessity of reduction in the price are required to be scrutinised very carefully - the Ld. Commissioner (Appeals) passed the impugned order only by relying the finding of lower adjudicating authority - In the instant case, the Ld. Commissioner (Appeals) has not examined the genuineness of the addendum, and has proceeded to reject the appeal of the appellant. - Matter restored back - AT
Valuation of Vessel - Whether the transaction value of the vessel is to be priced mentioned in the original MOA or the reduced price indicated in the addendum? - the genuineness and the necessity of reduction in the price are required to be scrutinised very carefully - the Ld. Commissioner (Appeals) passed the impugned order only by relying the finding of lower adjudicating authority - In the instant case, the Ld. Commissioner (Appeals) has not examined the genuineness of the addendum, and has proceeded to reject the appeal of the appellant. - Matter restored back - AT
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