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...
TDS u/s 195 - profit attributable to the PE in India - the privity of contract is between the assessee and Indian customers, wherein, CCPL has no role to play. The aforesaid factual position emerging on record could not be effectively controverted by the Revenue through proper evidence. - the assessee cannot be construed as a dependent agent PE of CCPL - CIT(A) rightly deleted the additions - AT
TDS u/s 195 - profit attributable to the PE in India - the privity of contract is between the assessee and Indian customers, wherein, CCPL has no role to play. The aforesaid factual position emerging on record could not be effectively controverted by the Revenue through proper evidence. - the assessee cannot be construed as a dependent agent PE of CCPL - CIT(A) rightly deleted the additions - AT
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