Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
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TP adjustment - tested party - As per Guidance Note on report u/s 92E and transfer pricing guidelines issued by the OECD and united nation practical manual of transfer pricing for developing country, the foreign Associate Enterprise(AE) can be selected as a tested party
TP adjustment - tested party - As per Guidance Note on report u/s 92E and transfer pricing guidelines issued by the OECD and united nation practical manual of transfer pricing for developing country, the foreign Associate Enterprise(AE) can be selected as a tested party
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