Re-computation of Arm's Length Price for Salaries: Consider Only Employees with Minimum Three Years' Service for Fairness.

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....TP Adjustment - re-computing the Arm’s Length price (ALP) of Salary payments made to related parties - payment of remuneration to the related persons - the employees have rendered service ranging from seven months to five years which provide a wide variance and thus, for comparability purposes, it would be appropriate to consider comparable cases who have rendered services for minimum three years and exclude other cases who have rendered services for a lesser period. - AT....