Introducing the “In Favour Of” filter in Case Laws.
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Introducing the “In Favour Of” filter in Case Laws.
Try it now in Case Laws →
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of In an intra AE situation, the transaction value of sale of shares cannot be said to be an uncontrolled price at all. Nothing, therefore, turns on the original agreement terms and it has no relevance in determination of arm’s length price. The very approach of the TPO is thus vitiated in law.
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