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 - nature of 'referral fee' paid outside India - No services were rendered in India by these two companies for facilitating the investment in the assessee company by these five companies. Merely reference of the 'consultancy charges' in the ledger of the assessee cannot be a ground to treat the charges paid by the assessee as consultancy charges - AT
TDS u/s 195 - nature of 'referral fee' paid outside India - No services were rendered in India by these two companies for facilitating the investment in the assessee company by these five companies. Merely reference of the 'consultancy charges' in the ledger of the assessee cannot be a ground to treat the charges paid by the assessee as consultancy charges - AT
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