Saturday, 3 January 2015

Transactions emanating from common contract are closely linked; to be aggregated to compute ALP by T

IT/ILT : Where two or more transactions emanate from common source being an order or contract or an agreement or an arrangement, then such transactions could be said to be closely linked as nature, characteristic and terms of such transactions substantially flow from said common source; where number of transactions are closely linked transactions, then same can be aggregated and construed as a single transaction for purpose of determining ALP


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