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Income Tax - Highlights / Catch Notes

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TPA - ALP adjustment in respect of royalty payment made - In the ...


Assessee-Company Must Justify Royalty Adjustments Under Transfer Pricing Agreement; Clubbing Transactions Without Justification is Prohibited.

May 30, 2017

Case Laws     Income Tax     AT

TPA - ALP adjustment in respect of royalty payment made - In the absence of justification, clubbing other transactions is not possible. The onus always lies on the assessee-company to establish the justification for clubbing and aggregation of the transaction of payment of royalty with other transactions.- AT

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