Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Consideration received in nature of reimbursement expenses along with mark up @ 10% - “royalty” and “Fee for included services” in equal proportion – matter has not been examined in the context of Indo-US treaty - matter remanded back - AT
Consideration received in nature of reimbursement expenses along with mark up @ 10% - “royalty” and “Fee for included services” in equal proportion – matter has not been examined in the context of Indo-US treaty - matter remanded back - AT
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