Friday 14 June 2013

Assessee can change his method for determining ALP before TPO if it exhibits a better result

IT/ILT : Assessee not precluded from pleading before TPO or the appellate courts that the method chosen and adopted by him as the most appropriate method ('MAM') for determining Arm's Length Price is not resulting into proper determination of ALP and some other method should be resorted to. Assessment authorities and appellate courts can take into consideration such a plea before them provided assessee demonstrates as to how a change in the method will produce better or more appropriate ALP in t


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