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...
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Issue concerns denial of exemption under charitable-trust law for part of salary paid to a specified officer on grounds of excessiveness; the legal point applied is assessment of reasonableness of remuneration by reference to role, responsibilities and relevant experience. The increase in salary was held to correspond to expanded duties and proven industry experience, and was approved by the entity's managing committee; as a result the challenged disallowance was not sustained and the payment was treated as reasonable for exemption purposes.
Issue concerns denial of exemption under charitable-trust law for part of salary paid to a specified officer on grounds of excessiveness; the legal point applied is assessment of reasonableness of remuneration by reference to role, responsibilities and relevant experience. The increase in salary was held to correspond to expanded duties and proven industry experience, and was approved by the entity's managing committee; as a result the challenged disallowance was not sustained and the payment was treated as reasonable for exemption purposes.
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