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 - Addition of notional interest @ 10 % on deposit made - interest having neither been accrued to the assessee (as per specific terms of the Agreement placed on record before us) and neither any interest having being received by the assessee, such interest cannot be subject to tax in the hands of the assessee on purely “notional basis” - AT
Accrual of income - Addition of notional interest @ 10 % on deposit made - interest having neither been accrued to the assessee (as per specific terms of the Agreement placed on record before us) and neither any interest having being received by the assessee, such interest cannot be subject to tax in the hands of the assessee on purely “notional basis” - AT
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