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...
TP Adjustment - adhoc adjustment - duty of the TPO is restricted only to the determination of the ALP of an international transaction between two related parties by applying any of the methods prescribed u/s.92C r.w. rule 10B and there is no provision made in the statute empowering TPO for determining the ALP on an estimation basis /adhoc basis - adjustment deleted
TP Adjustment - adhoc adjustment - duty of the TPO is restricted only to the determination of the ALP of an international transaction between two related parties by applying any of the methods prescribed u/s.92C r.w. rule 10B and there is no provision made in the statute empowering TPO for determining the ALP on an estimation basis /adhoc basis - adjustment deleted
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