Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
DTAA between India and the Swiss Confederation - Though a training activity may be connected to an engineering concern, that by itself, would not constitute training, to be an engineering activity so as to fall within “professional services” under Article 14 of the Treaty - AT
DTAA between India and the Swiss Confederation - Though a training activity may be connected to an engineering concern, that by itself, would not constitute training, to be an engineering activity so as to fall within “professional services” under Article 14 of the Treaty - AT
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