Wednesday 22 January 2014

TPO ought to have first analysed internal comparable before external once for making TP adjustment,

IT/ILT : Where TPO held that guarantee commission paid by AEs to assessee had to be benchmarked with external comparables, in view of fact that, internal CUP was available in case of assessee itself in form of guarantee charges, charged by bank from assessee, same ought to had been first analyzed and examined


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