Exemption for examination-related services rejected where recipients were commercial entities; suppression sustained extended limitation and penalties...
Determination of arm’s length price (ALP) - TPA - working capital adjustment has to be allowed based on the working capital requirements of the assessee and the comparable companies irrespective of the fact, whether such adjustment is negative or positive. - AT
Determination of arm’s length price (ALP) - TPA - working capital adjustment has to be allowed based on the working capital requirements of the assessee and the comparable companies irrespective of the fact, whether such adjustment is negative or positive. - AT
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