Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Fees for technical services (FTS) - nature of payment - the assessee was not exploiting the D&D for business purposes, that IPR of the D&D were retained by the non resident supplier - disputed amount cannot be considered as FTS - AT
Fees for technical services (FTS) - nature of payment - the assessee was not exploiting the D&D for business purposes, that IPR of the D&D were retained by the non resident supplier - disputed amount cannot be considered as FTS - AT
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