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TPO could only determine ALP of purchase of Know-how without questioning its justification for purchase

July 31, 2019[2019] 107 314 (Bombay)/[2019] 265 Taxman 204 (Bombay)

TRANSFER PRICING: Where TPO was of opinion that purchase of know­-how made by assessee from its AE was not at Arm's Length, he could have applied any specified methods for determining Arm's Length Price of transaction, however,could not have replaced business decision of assessee and recorded justification for purchase made in context of incremental benefit earned by assessee out of such know­-how

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