Thursday, 6 November 2014

Comparables with functional differences and related party transactions couldn't be chosen for TP stu

IT/ILT : Where TPO made addition to assessee's ALP in respect of software development services rendered to AE on basis of arithmetic mean margin of comparables selected under TNMM, since some of comparables selected by TPO was inappropriate on account of functional difference, export turnover and related party transactions etc., impugned addition was to be set aside


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