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...
Refund - Doctrine of unjust enrichment - It is on record that the amounts were deducted from their bills and the client had forced the Appellant to make the remittance to the Government. In such a case, when it is clear that no amount was recovered from the client and this amount has been remitted by way of GAR-7 Challans, there is no possibility of any unjust enrichment accruing to the Appellant, if refund claim is sanctioned. - AT
Refund - Doctrine of unjust enrichment - It is on record that the amounts were deducted from their bills and the client had forced the Appellant to make the remittance to the Government. In such a case, when it is clear that no amount was recovered from the client and this amount has been remitted by way of GAR-7 Challans, there is no possibility of any unjust enrichment accruing to the Appellant, if refund claim is sanctioned. - AT
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