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Income Tax - Highlights / Catch Notes

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TP Adjustment - payment of royalty - comparison in order to ...


Transfer Pricing: Royalty Payments Must Compare Controlled and Uncontrolled Transactions for Accurate Arm's Length Price Assessment.

September 15, 2021

Case Laws     Income Tax     AT

TP Adjustment - payment of royalty - comparison in order to determine if the ALP cannot be done by comparing the prices charged to by A.E. which is controlled transaction, as the provisions of I.T. Act, mandates that the determination of ALP has to be done by comparison between controlled and un-controlled transactions. - AT

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