Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
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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