Thursday 28 August 2014

Operating ratio couldn't be basis of comparison if assessee was doing trading and not agency busines

IT/ILT : Where assessee entered into transactions of sales and purchases of goods with its AE located abroad on principal to principal basis which were akin to trading transactions, authorities below were justified in rejecting assessee's contention that while determining ALP appropriate ratio to be considered for comparing with other entities would be ratio of net revenue to operating costs


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