TP Adjustment on export of Valves -ALP determination - TPO ought ...
TPO Must Use USA-Specific Comparisons for Arm's Length Price in Valve Export to Associated Enterprises.
May 10, 2019
Case Laws Income Tax HC
TP Adjustment on export of Valves -ALP determination - TPO ought to have arrived at the ALP of the respondent's sale to its A.E. by only comparing it with uncontrolled transaction of sale to in USA and not with sales to its AEs in different parts of the world - comparison has to be region /country specific
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