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Income Tax - Highlights / Catch Notes

Home Highlights January 2024 Year 2024 This

TP Adjustment - MAM - Considering brokerage rate of all Non-AEs ...

Case Laws     Income Tax

January 24, 2024

TP Adjustment - MAM - Considering brokerage rate of all Non-AEs for the comparability purposes - Arm's Length Price (ALP) of broking commissions - The Tribunal directed the Transfer Pricing Officer (TPO) to consider both overseas and domestic clients while applying the Comparable Uncontrolled Price (CUP) method. Adjustment of 40% was allowed on marketing and research costs. - AT

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