Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Re-computation of the ALP - idle capacity - PO used the TNMM as the most appropriate method for calculating the ALP - assessee could not point out that the utilization of employees by the comparable companies was less than the assessee - please of assessee rejected - AT
Re-computation of the ALP - idle capacity - PO used the TNMM as the most appropriate method for calculating the ALP - assessee could not point out that the utilization of employees by the comparable companies was less than the assessee - please of assessee rejected - AT
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