Forex cost mark-up was required while making salary payment to expat employee if salary was part of operating cost

TRANSFER PRICING: Where TPO, in respect of management network services rendered by assessee to its AE, made certain adjustment by taking a view that assessee should have billed 50 per cent of costs incurred under MNS business segment to its AE, since said apportionment of cost was made on ad hoc basis, impugned adjustment was to be set aside and, matter was to be remanded back for disposal afresh

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