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 issues: Royalty arrangement including trademark, know-how upheld based on CUP method over TNMM. Advertisement expenses remanded for fresh determination. Reimbursement of third-party advertisement expenses deleted as commercial expediency beyond TPO's jurisdiction. IT cost allocation and consultancy services/HR cost reimbursements deleted following past orders. Comparables for marketing support services: APITCO, HCCA Business Services, Quippo Valuers, TSR Darashaw excluded; ITDC (ARMS segment), Overseas Manpower, ICRA Management Consulting included based on functional comparability and consistency. TPO directed to recompute ALP for marketing support services accordingly.
Transfer pricing issues: Royalty arrangement including trademark, know-how upheld based on CUP method over TNMM. Advertisement expenses remanded for fresh determination. Reimbursement of third-party advertisement expenses deleted as commercial expediency beyond TPO's jurisdiction. IT cost allocation and consultancy services/HR cost reimbursements deleted following past orders. Comparables for marketing support services: APITCO, HCCA Business Services, Quippo Valuers, TSR Darashaw excluded; ITDC (ARMS segment), Overseas Manpower, ICRA Management Consulting included based on functional comparability and consistency. TPO directed to recompute ALP for marketing support services accordingly.
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