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Income Tax - Highlights / Catch Notes

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Determination of ALP - in case of service provider, the ALP of ...


Arm's Length Price for Importing Capital Equipment Must Reflect Costs, Including Depreciation; Cannot Be Set to Nil.

July 29, 2017

Case Laws     Income Tax     AT

Determination of ALP - in case of service provider, the ALP of import of capital equipment, the depreciation cost of which is recharged with a markup cannot be determined to be nil because it is a tax neutral transaction and revenue is dependent upon the cost incurred (which includes depreciation).

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