Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Valuation - royalty/ value of designs, drawings etc. - Only a portion of the lump sum amount attributable to the design cost of product manufactured abroad - only appropriate amount to be included in the value of import - AT
Valuation - royalty/ value of designs, drawings etc. - Only a portion of the lump sum amount attributable to the design cost of product manufactured abroad - only appropriate amount to be included in the value of import - AT
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