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ITAT deleted separate ALP computation on realization of sale proceeds from AE with extended credit period

January 30, 2019[2019] 101 taxmann.com 315 (Bangalore - Trib.)
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IT/ILT: In case of assessee rendering software development services to AE, companies having less than 15 per cent of related party transactions were to included as comparables

IT/ILT: Giving a credit period was an integral part of transaction of rendering of software development services by assessee to its AE and, therefore, there could be no separate determination of ALP of international transaction of realization of sale proceeds with extended credit period as it was only incidental to transaction of sale

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