Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Payments “accrued or arise” in India - taxability need to be determined u/s 5(2)(b) OR u/s 9(1) - there is no inherent contradiction between both the sections - AT
Payments “accrued or arise” in India - taxability need to be determined u/s 5(2)(b) OR u/s 9(1) - there is no inherent contradiction between both the sections - AT
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