Prospective valuation amendment limits reassessment: unamended fair market value reference could not justify reopening based on a registered valuer's ...
TP Adjustment - intra/group services in the nature of management services - DRP ignored the evidences filed by the assessee demonstrating receipt of management services by merely stating that the assessee failed the benefit test. - Adjustment made by the TPO by determining the arm’s length price of the management services at nil is unsustainable. - AT
TP Adjustment - intra/group services in the nature of management services - DRP ignored the evidences filed by the assessee demonstrating receipt of management services by merely stating that the assessee failed the benefit test. - Adjustment made by the TPO by determining the arm’s length price of the management services at nil is unsustainable. - AT
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