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Income Tax - Highlights / Catch Notes

Home Highlights December 2022 Year 2022 This

TP Adjustment - rejecting the Internal Transactional Net Margin ...

Income Tax

December 9, 2022

TP Adjustment - rejecting the Internal Transactional Net Margin Method (TNMM) as Most Appropriate Method (MAM) - effectively all the 12 comparables chosen by the assessee, on without prejudice basis, for applying External TNMM gets approved. - there is no scope for making any adjustment to arm’s length price even if External TNMM is adopted in the instant case. - AT

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