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...
Business expenditure claims for shortages and quality cuts were sent back for fresh verification because the lower authorities had rejected them for want of complete supporting evidence, while the Tribunal found no corroboration for the assumption that the goods remained in closing stock and noted that additional material had not yet been examined. The transfer pricing adjustment under the CUP method was also remanded because a disputed credit note appeared to involve only a clerical date error, and the revised arm's length computation with discounts and credit notes required verification. The omitted TDS credit was ordered to be granted because it had been acknowledged in the draft computation and was not denied by any DRP direction.
Business expenditure claims for shortages and quality cuts were sent back for fresh verification because the lower authorities had rejected them for want of complete supporting evidence, while the Tribunal found no corroboration for the assumption that the goods remained in closing stock and noted that additional material had not yet been examined. The transfer pricing adjustment under the CUP method was also remanded because a disputed credit note appeared to involve only a clerical date error, and the revised arm's length computation with discounts and credit notes required verification. The omitted TDS credit was ordered to be granted because it had been acknowledged in the draft computation and was not denied by any DRP direction.
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