TMI BlogTransfer pricing adjustment (TPA) - ALP determination - the contract termination fee also partakes the...Transfer pricing adjustment (TPA) - ALP determination - the contract termination fee also partakes the character of the contract receipt and is to be treated as operating revenue of the international transactions more particularly since the expenses incurred by the assessee on such contract has been taken as operating cost. - AT ..... X X X X Extracts X X X X X X X X Extracts X X X X
|