Arm's length pricing protected: specified domestic transactions at arm's length avoid disallowance for excessive expenditure. The amendment prevents disallowance for expenditures deemed excessive where a specified domestic transaction is at arm's length price as defined in the transfer pricing provisions. It also extends related party linkage for disallowance to include transactions with any company in which the first company has a substantial interest, thereby broadening the scope of scrutiny for domestic related party dealings.
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Provisions expressly mentioned in the judgment/order text.
Arm's length pricing protected: specified domestic transactions at arm's length avoid disallowance for excessive expenditure.
The amendment prevents disallowance for expenditures deemed excessive where a specified domestic transaction is at arm's length price as defined in the transfer pricing provisions. It also extends related party linkage for disallowance to include transactions with any company in which the first company has a substantial interest, thereby broadening the scope of scrutiny for domestic related party dealings.
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