Friday 17 April 2015

No TP addition by AO on basis of notional price instead of using actual price charged from non-AE un

IT/ILT : It is actual transaction of charging or paying price in a comparable uncontrolled transaction which is to be considered for purposes of determining ALP under CUP method and there can be no question of substituting such actual price charged with a notional price which could have been charged


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