Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
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TP Adjustment - rejecting the Internal Transactional Net Margin Method (TNMM) as Most Appropriate Method (MAM) - effectively all the 12 comparables chosen by the assessee, on without prejudice basis, for applying External TNMM gets approved. - there is no scope for making any adjustment to arm’s length price even if External TNMM is adopted in the instant case. - AT
TP Adjustment - rejecting the Internal Transactional Net Margin Method (TNMM) as Most Appropriate Method (MAM) - effectively all the 12 comparables chosen by the assessee, on without prejudice basis, for applying External TNMM gets approved. - there is no scope for making any adjustment to arm’s length price even if External TNMM is adopted in the instant case. - AT
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