Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
TPA - Jurisdiction of the AO in making the assessment without referring the matter to the Transfer Pricing Officer where the value of international transactions exceeded ₹ 5 crores - Transfer Pricing adjustments made by the AO in contradiction to the mandatory instructions of the CBDT is bad in law.- AT
TPA - Jurisdiction of the AO in making the assessment without referring the matter to the Transfer Pricing Officer where the value of international transactions exceeded ₹ 5 crores - Transfer Pricing adjustments made by the AO in contradiction to the mandatory instructions of the CBDT is bad in law.- AT
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