Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
TP Adjustment - benchmarking done by the assessee by adopting internal CUP - the comparable selected by the assessee is the correct comparable being payment of royalty for technology acquired for identical activity as availed by the assessee, while that of the TPO are for totally different activity - AT
TP Adjustment - benchmarking done by the assessee by adopting internal CUP - the comparable selected by the assessee is the correct comparable being payment of royalty for technology acquired for identical activity as availed by the assessee, while that of the TPO are for totally different activity - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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