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Income Tax - Highlights / Catch Notes

Home Highlights April 2017 Year 2017 This

TPA - 'operating profit’ from the international transaction is ...


Transfer Pricing Adjustments: Use Operating Profit, Not Net Profit, for TNMM Comparisons in International Transactions.

April 27, 2017

Case Laws     Income Tax     AT

TPA - 'operating profit’ from the international transaction is compared with the operating profit margin of the comparables under the TNMM. Thus the addition based on the transfer pricing adjustment, on the strength of `net profit’ as numerator in contrast to `operating profit’, cannot be upheld - AT

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