Transfer pricing adjustments - ALP - The proviso to sub. Rule 4 of Rule 10B does not mandate that always...

Transfer pricing adjustments - ALP - The proviso to sub. Rule 4 of Rule 10B does not mandate that always consider two more years' data of comparables in such analysis; but has a limited role only when the data of current year reveal some exceptional facts which could have influenced on determination of the Act in relation to the transaction being compared. - AT .....

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