Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
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TP addition - Specified Domestic Transaction (SDT) of Rent payment - Once it is held that the property was used by the assessee for its business purpose and the Revenue brought no contrary reliable evidence on record, the case of the TPO applying `Other method’ and determining Nil ALP on the ground that no independent party would have paid any rent for not having occupied the premises, fails. - AT
TP addition - Specified Domestic Transaction (SDT) of Rent payment - Once it is held that the property was used by the assessee for its business purpose and the Revenue brought no contrary reliable evidence on record, the case of the TPO applying `Other method’ and determining Nil ALP on the ground that no independent party would have paid any rent for not having occupied the premises, fails. - AT
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