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Income Tax - Highlights / Catch Notes

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TP Adjustment - Determination of Arms Length Price (ALP) - Once ...


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

March 7, 2020

Case Laws     Income Tax     AT

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

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