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Income Tax - Highlights / Catch Notes

Home Highlights September 2013 Year 2013 This

Transfer pricing adjustments - ALP - The proviso to sub. Rule 4 ...


Transfer Pricing Rule 10B: No Mandatory Use of Two-Year Comparable Data Unless Current Year Shows Exceptions.

September 14, 2013

Case Laws     Income Tax     AT

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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