Alternate statutory remedy governs GST assessment challenge, with statutory appeal preserved and limitation objection barred for the permitted filing ...
ALP of the international transaction of payment of Fees for Management services - 5% mark-up under Cost plus method - Even if, we proceed with the assumption that the mark up of 5% is not at ALP, which should be as low as 1% or even less than that, still the difference arising on account of such mark-up going even up to 0% in a comparable uncontrolled situation, would be within +/-5% range, not requiring any TP adjustment
ALP of the international transaction of payment of Fees for Management services - 5% mark-up under Cost plus method - Even if, we proceed with the assumption that the mark up of 5% is not at ALP, which should be as low as 1% or even less than that, still the difference arising on account of such mark-up going even up to 0% in a comparable uncontrolled situation, would be within +/-5% range, not requiring any TP adjustment
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