TP Adjustment - US Transactions non US Transactions - scope of ...

Income Tax

December 23, 2023

TP Adjustment - US Transactions non US Transactions - scope of MAP agreement - It would be better to refer to the settlement arrived between the competent authority of India and the competent authority of USA to resolve the cases relating to Hewitt India for A.Y. 2006-07 to 2010-11 by adopting the values relating to US related international transaction - No hesitation to direct the AO / TPO to adopt the same approach for the non US transactions as adopted in the MAP for US transactions and determine the TP adjustment, if any, after affording a reasonable and sufficient opportunity of being heard to the assessee. - AT

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TP Adjustment - US Transactions non US Transactions - scope of ...

Income Tax

December 23, 2023

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