Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Transfer pricing adjustment - Method of computation of operating profit - Rejection of comparables - matter remitted back to AO to consider the assessee's claim with regard to idle capacities after due consideration of all materials available on record and affording a reasonable opportunity - AT
Transfer pricing adjustment - Method of computation of operating profit - Rejection of comparables - matter remitted back to AO to consider the assessee's claim with regard to idle capacities after due consideration of all materials available on record and affording a reasonable opportunity - AT
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