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Income Tax - Highlights / Catch Notes

Home Highlights April 2020 Year 2020 This

TP Adjustment - comparable selection - filters applied by Ld.TPO ...


Tax Authorities Urged to Reassess Comparables Selection in Transfer Pricing Case Involving Limited Managerial Functions.

April 11, 2020

Case Laws     Income Tax     AT

TP Adjustment - comparable selection - filters applied by Ld.TPO - assessee is not involved in any of the strategic functions and is only undertaking preliminary tactical managerial functions. Assessee also does not undertake any marketing/business development activity. Further it is observed that assessee do not undertake any key risks. Based upon the above in our view the comparables needs to be revisited. - AT

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