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Income Tax - Highlights / Catch Notes

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TP Adjustment - MAM selection - once TNMM has been accepted ...

Income Tax

October 25, 2023

TP Adjustment - MAM selection - once TNMM has been accepted under the similar FAR, there is no reason to deviate by adopting CUP Method and other methods admittedly are incapable of capturing the true arm's length result and therefore, we hold that TNMM should be taken as a most appropriate method for benchmarking the said transaction. - AT

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