Taxpayer's Comparables Rejected by TPO; Internal TNMM u/r 10B Scrutinized for Transfer Pricing Compliance.

TP Adjustment - TPO rejected the comparables selected by the assessee - As assessee, has applied the internal TNMM method as most appropriate and from the aforesaid rule we note that the rule 10B of the rules has to be apply to select the method for the purpose to determine the ALP and TNMM method could be applied as internal as well as external. - AT .....

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