21 results for “transfer pricing”+ Section 16A(6)clear
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In the result, both the appeals of the assessee are partly allowed for statistical purposes
Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy
6. Detailed workings pertaining to derivation of allocation rate per hour; 7. Corroborative benchmarking analysis conducted by the assessee with AE as the tested party, to demonstrate the arm’s length nature of pricing of the international transaction. 18.2 The assessee also submitted a detailed note on the various services availed by them under the terms of the agreement. Further