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...
Validity of assessment order - Amalgamation - transfer pricing order u/s. 92CA(3) was passed against non-est (amalgamated) company - assessment order though passed in the name of the amalgamated company is held to be invalid for the reason that the draft assessment order and the transfer pricing order passed by the A.O./TPO was in the name of the non existing company. - AT
Validity of assessment order - Amalgamation - transfer pricing order u/s. 92CA(3) was passed against non-est (amalgamated) company - assessment order though passed in the name of the amalgamated company is held to be invalid for the reason that the draft assessment order and the transfer pricing order passed by the A.O./TPO was in the name of the non existing company. - AT
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