Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
TP Adjustment - share application money remained parked with AE - nothing on record to prove that transaction was sham - TPO could not have treated such transaction as a loan and charged interest thereon on notional basis.
TP Adjustment - share application money remained parked with AE - nothing on record to prove that transaction was sham - TPO could not have treated such transaction as a loan and charged interest thereon on notional basis.
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