TP Adjustment - Determination of ALP - The Appellant had ...
Call Option Exercise Valid Under Shareholders Agreement; 'Other Method' Chosen for Arm's Length Price Determination.
September 5, 2023
Case Laws Income Tax AT
TP Adjustment - Determination of ALP - The Appellant had acquired shares from the promoter (i.e. Viney Sagar Sahgal) by triggering call option in terms of Shareholders Agreement. There is nothing on record to show that the exercise of call option had no impact on the determination of sale price. - ‘Other Method’ be adopted as the most appropriate method - AT
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