Parent Firm Must Charge for Support Services; 5% Markup Deemed Fair for Transfer Pricing Adjustment 'sLength.

TP Adjustment - ALP adjustment on account of profit mark-up - It cannot be expected that the parent organization supply support services without charging anything for such services rendered. Hence, we hold that the markup of 5% is sufficient to recoup the expenditure involved by the AE in exploration, inspection, testing and finalization of the suitable software. - AT .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X