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 - Disallowance of commission, brokerage and discount expenses - in the instant case where the overseas agents were paid commission for securing order etc., and such services were utilised for the purpose of making or earning income from a source outside India, the assessee is under no obligation to apply with provisions of Section 195 for the reasons that commission to such overseas agents are not taxable under the Act. - Additions deleted - AT
TDS u/s 195 - Disallowance of commission, brokerage and discount expenses - in the instant case where the overseas agents were paid commission for securing order etc., and such services were utilised for the purpose of making or earning income from a source outside India, the assessee is under no obligation to apply with provisions of Section 195 for the reasons that commission to such overseas agents are not taxable under the Act. - Additions deleted - AT
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