Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
TP Adjustment - TPO rejected the comparables selected by the assessee - As assessee, has applied the internal TNMM method as most appropriate and from the aforesaid rule we note that the rule 10B of the rules has to be apply to select the method for the purpose to determine the ALP and TNMM method could be applied as internal as well as external. - AT
TP Adjustment - TPO rejected the comparables selected by the assessee - As assessee, has applied the internal TNMM method as most appropriate and from the aforesaid rule we note that the rule 10B of the rules has to be apply to select the method for the purpose to determine the ALP and TNMM method could be applied as internal as well as external. - AT
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