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Revenue-neutral specified domestic transfer pricing for...
Revenue-neutral domestic transfer pricing and mirror transactions justified deletion of related-party adjustments for operation, maintenance and port services.
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Revenue-neutral specified domestic transfer pricing for operation and maintenance services did not justify an adjustment where both related entities were taxable in India and eligible for the same deduction, with no demonstrated base erosion or diversion outside the tax net; the deletion of that adjustment was upheld. For sale of port services, the corresponding mirror transaction had already been accepted as at arm's length in the counter-party's hands, so the deletion of that adjustment was also upheld.
Revenue-neutral specified domestic transfer pricing for operation and maintenance services did not justify an adjustment where both related entities were taxable in India and eligible for the same deduction, with no demonstrated base erosion or diversion outside the tax net; the deletion of that adjustment was upheld. For sale of port services, the corresponding mirror transaction had already been accepted as at arm's length in the counter-party's hands, so the deletion of that adjustment was also upheld.
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