Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Transfer Pricing Adjustments - benchmarking the purchase of SIM cards by the assessee from its AEs - selection of MAM - CUP v/s RPM - CIT(A) has incorrectly applied the CUP method based on incomplete data, ignoring geographical differences and contrary to the Assessee’s own TP Analysis and contrary to TP Auditor’s Report. CIT(A) has also erroneously aggregated the transactions despite judicial pronouncements on the issue. - AT
Transfer Pricing Adjustments - benchmarking the purchase of SIM cards by the assessee from its AEs - selection of MAM - CUP v/s RPM - CIT(A) has incorrectly applied the CUP method based on incomplete data, ignoring geographical differences and contrary to the Assessee’s own TP Analysis and contrary to TP Auditor’s Report. CIT(A) has also erroneously aggregated the transactions despite judicial pronouncements on the issue. - AT
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