Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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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