Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
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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