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Income Tax - Highlights / Catch Notes

Home Highlights March 2021 Year 2021 This

TP adjustment in Distribution activity, described as ESAS - ALP ...

Case Laws     Income Tax

March 8, 2021

TP adjustment in Distribution activity, described as ESAS - ALP and the consequential transfer pricing adjustment are contemplated only in respect of the international transactions and not the entity level transactions. The TPO, in the instant case computed transfer pricing adjustment in respect of entity level transactions. We direct to restrict it to the AE transactions under consideration and not the entity level transactions. - AT

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