Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
The disputed transactions were speculative and not hedging transaction - assessee could not relate any single bill to any of the contract and it had not provided detail of any purchase order relatable to specific transaction - AT
The disputed transactions were speculative and not hedging transaction - assessee could not relate any single bill to any of the contract and it had not provided detail of any purchase order relatable to specific transaction - AT
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