Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
TPA - selection of MAM for determining ALP of transaction - APM v/s RPM - Ld.AO/TPO erred in not conducting fresh search of comparables which would have strict functional similarity while using RPM as MAM.
TPA - selection of MAM for determining ALP of transaction - APM v/s RPM - Ld.AO/TPO erred in not conducting fresh search of comparables which would have strict functional similarity while using RPM as MAM.
Note: It is a system-generated summary and is for quick reference only.