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Tax Authority Confirms Additions: Assessee's Role Limited to Marketing; AE Retains Product Ownership, Decision-Making, and Pricing Authority.
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....TP Adjustment - Assessee's main activity is nothing but marketing activity, whereas all the ownership of the product, the power to determine whether to accept / reject the order and the pricing is with the AE. The assessee is only getting 3.5% of the revenue from the receipts of the customers for the marketing function that it is doing. - Additions confirmed - AT....