Section 10A and related deductions: Tribunal rejects separate-undertaking claim, but allows loss set-off, ESOP cost and foreign tax credit in principl...
Transfer pricing adjustments - selection of internal comparables - TPO had no mandate to have recourse to external comparables when in the present case, internal comparables were available, which could be applied for determining the ALP - AT
Transfer pricing adjustments - selection of internal comparables - TPO had no mandate to have recourse to external comparables when in the present case, internal comparables were available, which could be applied for determining the ALP - AT
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