Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Income accrued in India - taxability of receipt towards Infrastructure and Hosting Data Centre (IDC) charges by treating it as royalty - India–Singapore DTAA - the amount received by the assessee from provision of IDC services cannot be treated as royalty or FTS - No tax liability - AT
Income accrued in India - taxability of receipt towards Infrastructure and Hosting Data Centre (IDC) charges by treating it as royalty - India–Singapore DTAA - the amount received by the assessee from provision of IDC services cannot be treated as royalty or FTS - No tax liability - AT
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