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Income Tax - Highlights / Catch Notes

Home Highlights January 2021 Year 2021 This

TP Adjustment - royalty paid by the assessee to its AE - the TPO ...


TPO Cannot Question Commercial Expediency of Royalty Transactions; Limited to Arm's Length Price Assessment.

January 14, 2021

Case Laws     Income Tax     AT

TP Adjustment - royalty paid by the assessee to its AE - the TPO is not vested with any jurisdiction to question the commercial expediency of the transaction carried out by the assessee with its AE, and his jurisdiction is restricted to determining of the arm’s length price of the transaction - AT

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