Thursday, 14 May 2015

No TP adjustments in transactions with AE & non AE on basis of avg. operating profit margin of compa

IT/ILT : Under TNMM, it is not permissible to make transfer pricing adjustment by applying average operating profit margin of comparables on assessee's transactions with both AEs and non-AEs; inclusion of costs relevant to transactions with non-AEs, is not justified

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