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...
A registered recipient may seek an advance ruling where the transaction affects its tax position, because the term "applicant" is broad enough to cover such a request; the locus objection was therefore rejected and the ruling was examined on merits. On classification, crushing, screening and sizing of limestone/dolomite did not amount to manufacture because the processes did not produce a new product with a distinct name, character and use; the mineral identity and commercial understanding remained unchanged, with only physical dimensions altered. The contractor's assumption of operational risk was irrelevant. The activity was treated as treatment or processing of another person's goods and therefore a supply of service in the nature of job work.
A registered recipient may seek an advance ruling where the transaction affects its tax position, because the term "applicant" is broad enough to cover such a request; the locus objection was therefore rejected and the ruling was examined on merits. On classification, crushing, screening and sizing of limestone/dolomite did not amount to manufacture because the processes did not produce a new product with a distinct name, character and use; the mineral identity and commercial understanding remained unchanged, with only physical dimensions altered. The contractor's assumption of operational risk was irrelevant. The activity was treated as treatment or processing of another person's goods and therefore a supply of service in the nature of job work.
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