Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
TPA - the payment is made as per the approval given by the RBI and SIA, Government of India - there cannot be any scope of doubt that the royalty payment on technical knowhow is not at arm’s length - AT
TPA - the payment is made as per the approval given by the RBI and SIA, Government of India - there cannot be any scope of doubt that the royalty payment on technical knowhow is not at arm’s length - AT
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