Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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TP Adjustment - MAP Settlement - the provisions of the amended Rule 44G(5) stipulate that there shall not be a decrease in the income or increase in the loss of an assessee in the return of income of a given year, if the MAP is invoked on account of action taken by any income tax authority in India. - The petitioner in this case, for the reasons discussed and the provisions of amended Rule 44G(5), would be entitled to seek precedence to the MAP Settlement. This is also so because of article 27(2) of the DTAA - HC
TP Adjustment - MAP Settlement - the provisions of the amended Rule 44G(5) stipulate that there shall not be a decrease in the income or increase in the loss of an assessee in the return of income of a given year, if the MAP is invoked on account of action taken by any income tax authority in India. - The petitioner in this case, for the reasons discussed and the provisions of amended Rule 44G(5), would be entitled to seek precedence to the MAP Settlement. This is also so because of article 27(2) of the DTAA - HC
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