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Income Tax - Highlights / Catch Notes

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TP Adjustment - The Legislature has never shown an intention to ...

Income Tax

February 7, 2020

TP Adjustment - The Legislature has never shown an intention to treat the same international transaction in two different ways in the hands of two associated enterprises such that there would be arm’s length price adjustment at least in the hands of one of the associated enterprises. Hence, the approach adopted by the DRP/TPO is not acceptable.

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