Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Transfer pricing adjustment - agreement was between the Indian PSU and the Indian subsidiary of two non resident companies - transaction, cannot be presumed to be international transaction, even when the revenue authorities have tried to include it as the deemed transactions, - AT
Transfer pricing adjustment - agreement was between the Indian PSU and the Indian subsidiary of two non resident companies - transaction, cannot be presumed to be international transaction, even when the revenue authorities have tried to include it as the deemed transactions, - AT
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