Wednesday, 3 September 2014

TP adjustment for transactions with AE set aside as comparables had functional differences and highe

IT/ILT : Where TPO made addition to assessee's ALP in respect of software research and development support services rendered to its AE, in view of fact that some of comparables selected by TPO were improper on account of functional difference and high turnover, impugned adjustment was to be set aside and, matter was to be remanded back for disposal afresh


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