TPA - this is not a pure reimbursement of cost but cost sharing ...
ERP System Cost-Sharing Requires Markup Under Transfer Pricing Rules for Assessee Company Services.
November 24, 2014
Case Laws Income Tax AT
TPA - this is not a pure reimbursement of cost but cost sharing exercise in implementing ERP systems in the group - It certainly involves services by assessee company - mark up is warranted under the TP provisions. - AT
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