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Income Tax - Highlights / Catch Notes

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

Case Laws     Income Tax

March 23, 2024

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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