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Income Tax - Highlights / Catch Notes

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


Revenue Can't Challenge Officer's ALP Ruling; MAP Margins to Apply to Non-USA Transactions u/s 92CA.

May 18, 2021

Case Laws     Income Tax     AT

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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