Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
TPA - the TPO and the DRP were in error in holding that the nature of services rendered by ANPAP were in the nature of stewardship activity or shareholder activity - The charges paid by the Assessee to ANPAP are held to be at Arm’s Length - no additions - AT
TPA - the TPO and the DRP were in error in holding that the nature of services rendered by ANPAP were in the nature of stewardship activity or shareholder activity - The charges paid by the Assessee to ANPAP are held to be at Arm’s Length - no additions - AT
Note: It is a system-generated summary and is for quick reference only.