Thursday 3 April 2014

TPO couldn't consider profitability at entity level while determining ALP of a particular product, s

IT/ILT : Where assessee-company was importing raw material used in manufacturing and export of Akulon, in course of transfer pricing proceedings, TPO could not make adjustment to assessee's ALP by considering overall profitability from 'sale of manufactured finished goods to non-AEs', and not on basis of profitability in Akulon product segment alone


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