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Income Tax - Highlights / Catch Notes

Home Highlights May 2021 Year 2021 This

Enhancement u/s 92CA - “MAP” margin - the Revenue fails to ...

Income Tax

May 18, 2021

Enhancement u/s 92CA - “MAP” margin - the Revenue fails to dispute that even the Transfer Pricing Officer has not drawn any distinction qua the “ALP” in all the substantive grounds raised herein. We thus hold that the “MAP” margin of 15.49%, 15.34% and 15.76% deserves to be applied qua the remaining portion of non-USA based international transactions as well. - AT

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