Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Transfer pricing adjustment - adjustment made on account of sharing of software expenses with the AE - no reason why adjustment should be made on account of sharing of software expenses with the AE. The TPO has also not given any reason to treat the subscription value as nil. - AT
Transfer pricing adjustment - adjustment made on account of sharing of software expenses with the AE - no reason why adjustment should be made on account of sharing of software expenses with the AE. The TPO has also not given any reason to treat the subscription value as nil. - AT
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