TP Adjustment - benchmarking done by the assessee by adopting ...

Assessee's Internal CUP Method for Royalty Payments Upheld Over TPO's Different Activity Comparison.

March 24, 2023

Case Laws Income Tax AT

TP Adjustment - benchmarking done by the assessee by adopting internal CUP - the comparable selected by the assessee is the correct comparable being payment of royalty for technology acquired for identical activity as availed by the assessee, while that of the TPO are for totally different activity - AT

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TP Adjustment - benchmarking done by the assessee by adopting ...

Assessee's Internal CUP Method for Royalty Payments Upheld Over TPO's Different Activity Comparison.

March 24, 2023

Case Laws Income Tax AT

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