In an intra AE situation, the transaction value of sale of ...

Income Tax

September 5, 2018

In an intra AE situation, the transaction value of sale of shares cannot be said to be an uncontrolled price at all. Nothing, therefore, turns on the original agreement terms and it has no relevance in determination of arm’s length price. The very approach of the TPO is thus vitiated in law.

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In an intra AE situation, the transaction value of sale of ...

Income Tax

September 5, 2018

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