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Income Tax - Highlights / Catch Notes

Home Highlights February 2020 Year 2020 This

TP Adjustment - The Legislature has never shown an intention to ...


Dispute Panel's Approach Rejected: Arm's Length Price Adjustment Must Apply Equally to Associated Enterprises in International Transactions.

February 7, 2020

Case Laws     Income Tax     AT

TP Adjustment - The Legislature has never shown an intention to treat the same international transaction in two different ways in the hands of two associated enterprises such that there would be arm’s length price adjustment at least in the hands of one of the associated enterprises. Hence, the approach adopted by the DRP/TPO is not acceptable.

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