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Income Tax - Highlights / Catch Notes

Home Highlights November 2015 Year 2015 This

Transfer pricing adjustment - Ex consequenti, the “total cost” ...

Case Laws     Income Tax

November 18, 2015

Transfer pricing adjustment - Ex consequenti, the “total cost” being the denominator in the PLI of OP/TC, has to be taken as the cost incurred by the assessee and not the FOB value of goods between third party enterprises sourced through the assessee. In other words, the tested party should be the assessee and not its AE - AT

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