2024 (11) TMI 1164

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..... ot? - As decided by HC [ 2015 (12) TMI 1188 - DELHI HIGH COURT] Revenue has been unable to demonstrate by some tangible material that there is an international transaction involving AMP expenses between WOIL and Whirlpool USA. In the absence of that first step, the question of determining the ALP of such a transaction does not arise. HELD THAT:- We are not inclined to entertain the Special Leave P .....

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