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Income Tax - Highlights / Catch Notes

Home Highlights December 2018 Year 2018 This

TPA on AMP computed by the TPO using BLT - Comparison of the AMP ...


Court Rejects Transfer Pricing Adjustment on AMP Expenses Due to Misapplication of Bright Line Test by TPO.

December 5, 2018

Case Laws     Income Tax     AT

TPA on AMP computed by the TPO using BLT - Comparison of the AMP over sales ratio of the assessee with the AMP ratio of Pepsi Co Group on a worldwide basis was nothing but a distorted version of the BLT - Cannot sustain.

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