Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
TP adjustment - scope of Mutually Agreed Procedure (MAP) for determining the tax between India & USA - once CBDT in the later year agreed that transfer pricing consideration in relation to US based transactions can be safely adopted for the purpose of the assessee's non-US based transactions then it would be wholly inappropriate to allow the revenue to argue to the contrary
TP adjustment - scope of Mutually Agreed Procedure (MAP) for determining the tax between India & USA - once CBDT in the later year agreed that transfer pricing consideration in relation to US based transactions can be safely adopted for the purpose of the assessee's non-US based transactions then it would be wholly inappropriate to allow the revenue to argue to the contrary
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