Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Business Auxiliary Services - appellant is bottling and marketing of beverages under trade name Coca Cola, Kinley, Sprite etc - any activity which has been undertaken by a person on his own account for himself cannot be said to be covered by the 'service' even if this activity is undertaken by the person with the financial assistance/ support of other person either partially or completely - no activity has been performed for Coca Cola India
Business Auxiliary Services - appellant is bottling and marketing of beverages under trade name Coca Cola, Kinley, Sprite etc - any activity which has been undertaken by a person on his own account for himself cannot be said to be covered by the 'service' even if this activity is undertaken by the person with the financial assistance/ support of other person either partially or completely - no activity has been performed for Coca Cola India
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