Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
The royalty paid by the appellant to their holding company in USA towards the that receipt and use of software does does not fall under the 'Intellectual Property Service' - Demand set aside
The royalty paid by the appellant to their holding company in USA towards the that receipt and use of software does does not fall under the 'Intellectual Property Service' - Demand set aside
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