Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
DRP had summarily upheld the change from TNMM to CUP method without assigning any cogent reason whatsoever. By no means it is justified to keep on finding a method for addition by trial and error method - there was no justification in rejecting the TNMM method applied by the assessee as in the preceding year - AT
DRP had summarily upheld the change from TNMM to CUP method without assigning any cogent reason whatsoever. By no means it is justified to keep on finding a method for addition by trial and error method - there was no justification in rejecting the TNMM method applied by the assessee as in the preceding year - AT
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