Arm's Length Price in Transfer Pricing Adjustments must involve chargeable income; capital receipts aren't included unless stated in Section 2(24).

TPA - determination of ALP - income should be chargeable under the Act, before Chapter X can be applied - the definition of income does not include within its scope capital receipts arising out of capital account transaction unless so specified in Section 2(24) of the Act as income - HC .....

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