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...
Liability for non-registration turned on allocation of operational roles under the MOU and Guidelines: uploading contracts to the foreign online portal was the foreign authority's distinct obligation, while the domestic authority's duty arose only to verify entries already reflected on that portal; consequently the domestic authority could not be held liable for the foreign authority's failure to upload. Challenges to fixation of the Country Cap and its allocation raised economic policy issues; the court declined to substitute judgment for a plausible policy decision absent manifest arbitrariness, unreasonableness, or mala fides, and found no violation of equality or trade rights.
Liability for non-registration turned on allocation of operational roles under the MOU and Guidelines: uploading contracts to the foreign online portal was the foreign authority's distinct obligation, while the domestic authority's duty arose only to verify entries already reflected on that portal; consequently the domestic authority could not be held liable for the foreign authority's failure to upload. Challenges to fixation of the Country Cap and its allocation raised economic policy issues; the court declined to substitute judgment for a plausible policy decision absent manifest arbitrariness, unreasonableness, or mala fides, and found no violation of equality or trade rights.
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