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TP provisions not applicable on issue of shares to foreign AE; ITAT follows ratio of ‘Vodafone’ case

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  • TP provisions not applicable on issue of shares to foreign AE; ITAT follows ratio of ‘Vodafone’ case
Posted onon September 8, 2015

Tenet Tax Daily September 08 2015

By tenettax-team
Corporate Tax, International Tax

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Forex gain or loss, being an operating item would be adjusted while calculating margin of comparables
Delhi ITAT rejects ‘bright line test’ for adjustment of AMP exp. by following ratio of ‘Sony Ericsson’ case

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