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 - upward adjustment in imputing notional interest on the outstanding overdue receivables from Associated Enterprises - working capital adjustments on the ALP has been already factored in its pricing / profitability vis-à-vis that of its comparables - any further adjustment to the margin of the assessee on the outstanding receivables cannot be justified and no separate upward adjustment on outstanding export receivables is required - AT
TP adjustment - upward adjustment in imputing notional interest on the outstanding overdue receivables from Associated Enterprises - working capital adjustments on the ALP has been already factored in its pricing / profitability vis-à-vis that of its comparables - any further adjustment to the margin of the assessee on the outstanding receivables cannot be justified and no separate upward adjustment on outstanding export receivables is required - AT
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