Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
TP adjustment - without factoring in the difference in FAR, the comparison done by the TPO is not sustainable - there is no proper reason to apply CUP method, instead of that consistently applied earlier method of TNMM, as the most appropriate method (MAM).
TP adjustment - without factoring in the difference in FAR, the comparison done by the TPO is not sustainable - there is no proper reason to apply CUP method, instead of that consistently applied earlier method of TNMM, as the most appropriate method (MAM).
Note: It is a system-generated summary and is for quick reference only.