Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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Transfer-pricing adjustment for intra-group management, sales and support services was deleted after the Tribunal applied a co-ordinate Bench decision to the material facts. The adjustment had determined the arm's length price of those services at nil. The appeal was allowed on this issue, while the remaining grounds were left open.
Transfer-pricing adjustment for intra-group management, sales and support services was deleted after the Tribunal applied a co-ordinate Bench decision to the material facts. The adjustment had determined the arm's length price of those services at nil. The appeal was allowed on this issue, while the remaining grounds were left open.
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