Monday 3 March 2014

Internal comparable to be preferred over external one except if transactions between AE and non- AEs

IT/ILT: In course of determining ALP, preference should be given to internal uncontrolled comparables over external uncontrolled comparables, however, if nature of transaction with AE is different from that with non-AE or data in respect of two segments is either not workable or not reliable, then assistance from such internally comparable uncontrolled transactions should be avoided


No comments:

Post a Comment