Wednesday, 13 August 2014

TP adjustments on basis of comparables with divergent operations and related party transactions aren

IT/ILT: Where TPO made adjustment to assessee's ALP in respect of providing software development services to its AE, in view of fact that some of comparables selected by TPO were improper on account of functional difference, brand value, turnover, related party transactions etc., impugned adjustment was to be set aside and, matter was to be remanded back for disposal afresh


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