TPO Review: Regional Service Charges Provide Tangible Benefits, Not Shareholder Services, Valid for Business Operations.

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....TP Adjustment - international transaction of `Payment of Regional Service charges (RSC)’ - TPO has referred to regional services being in the nature of shareholder services in a generic sense. He has not specifically spelt out which services are shareholder services. From the detailed narration of services above, it is more than overt that the services did produce effect to the assessee company. As such, they go outside the ambit of the shareholder services. - the assessee availed the regional services in the carrying on its business at the transacted value. - AT....