TP Adjustment - payment of technical knowhow fees - benchmarking ...
Case Laws Income Tax
October 19, 2023
TP Adjustment - payment of technical knowhow fees - benchmarking of the transaction - Intragroup services or for that matter any international transaction is required to be benchmarked each year based on the facts and circumstances prevailing in that year considering the economic conditions. Therefore, the findings of the previous year will have only persuasive value, if any, while deciding the transfer pricing adjustment for any year. - AT
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