Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
TP adjustment - determining the Arm’s Length Price - if the ITAT has given detailed reasons for not remanding the issue to the TPO and the view taken is a plausible one then order of ITAT does not give rise to any substantial question of law
TP adjustment - determining the Arm’s Length Price - if the ITAT has given detailed reasons for not remanding the issue to the TPO and the view taken is a plausible one then order of ITAT does not give rise to any substantial question of law
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