Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Nature of receipts - royalty / FIR or reimbursement of expenses - The appellant is merely arranging Corporate IT services. The payments are received for such services and not for the right to use of equipment (hardware or software) - Such payments were not in the nature of royalty or FIS - AT
Nature of receipts - royalty / FIR or reimbursement of expenses - The appellant is merely arranging Corporate IT services. The payments are received for such services and not for the right to use of equipment (hardware or software) - Such payments were not in the nature of royalty or FIS - AT
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