Disallowed Expenditures Must Be Excluded from Operating Expenses in Arm's Length Price Calculations for Transfer Pricing Adjustments.

TP Adjustment - Determination of Arms Length Price (ALP) - Once a particular expenditure itself is disallowed, there can be no question of including it in the Operating expenses for calculating the profit margin in the process of determination of the ALP. - AT .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X