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Income Tax - Highlights / Catch Notes

Home Highlights February 2021 Year 2021 This

TP Adjustment - in case if a TP adjustment is allowed in respect ...

Case Laws     Income Tax

February 25, 2021

TP Adjustment - in case if a TP adjustment is allowed in respect of transactions entered into by the assessee with unrelated third parties then the same would be result into increasing of the profit in respect of such independent transactions which would be beyond the scope and ambit of Chapter X of the Act. Apparently, the claim of the ld. A.R that the TPO had wrongly worked out the TP adjustment in respect of the AE transactions by considering the total operating costs instead of the operating costs attributable to the AE sales is prima facie found to be correct. - AT

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