Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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The dominant issue was the appropriate gross profit rate to be applied for determining value/profit on alleged clandestine sales. The tribunal applied a gross profit rate of 12.5% based on particulars furnished by the appellant and consistent with prior judicial precedents, including binding decisions of the same court, and this application was found to be justified on the record. Consequently, no substantial question of law arose for consideration, and the appeal was dismissed. - HC
The dominant issue was the appropriate gross profit rate to be applied for determining value/profit on alleged clandestine sales. The tribunal applied a gross profit rate of 12.5% based on particulars furnished by the appellant and consistent with prior judicial precedents, including binding decisions of the same court, and this application was found to be justified on the record. Consequently, no substantial question of law arose for consideration, and the appeal was dismissed. - HC
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