Transfer Pricing Adjustment - arm's length price (ALP) of ...

Tribunal Rejects TPO's Transfer Pricing Approach, Orders Removal of Unjustified Adjustment for Functional Dissimilarity.

March 23, 2024

Case Laws Income Tax AT

Transfer Pricing Adjustment - arm's length price (ALP) of international transactions- MAM - “other method” - The Tribunal analyzed the transfer pricing methods applied and found fault with the TPO's approach. It determined that the comparables used were not suitable, considering the functional dissimilarity with the assessee. Moreover, the rejection of the "other method" used by the assessee was deemed unjustified. Consequently, the Tribunal directed the deletion of the adjustment made by the TPO.

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Transfer Pricing Adjustment - arm's length price (ALP) of ...

Tribunal Rejects TPO's Transfer Pricing Approach, Orders Removal of Unjustified Adjustment for Functional Dissimilarity.

March 23, 2024

Case Laws Income Tax AT

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