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No TP adjustment when it was held that foreign entity should have charged higher amount from Indian entities
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International Tax
No TP adjustment when it was held that foreign entity should have charged higher amount from Indian entities
Posted on
on
November 7, 2016
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By
tenettax-team
International Tax
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FAR analysis can’t be insisted upon in TNMM in transfer pricing
Sec. 254 doesn’t permit Tribunal to substitute a view which it believes should have been taken in first instance