Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Valuation - pure agent - inclusion of reimbursement of expenses - It was only stated that it was found by Audit Officers that the conditions of Pure Agent were not satisfied by the appellant - the allegations are bald and the SCN is not sustainable - AT
Valuation - pure agent - inclusion of reimbursement of expenses - It was only stated that it was found by Audit Officers that the conditions of Pure Agent were not satisfied by the appellant - the allegations are bald and the SCN is not sustainable - AT
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