Penalty under Section 112 fails where knowledge, admissible statements, and incriminating evidence are not proved against the Customs Broker's directo...
TP Adjustment - ALP of the royalty paid AE - royalty paid by other group entities are controlled transactions whereas, rule 10B(1)(a) mandates that the price charged for an uncontrolled transaction/transaction should be considered as a CUP - the determination of arm's length price as approved by the RBI/SIA is valid
TP Adjustment - ALP of the royalty paid AE - royalty paid by other group entities are controlled transactions whereas, rule 10B(1)(a) mandates that the price charged for an uncontrolled transaction/transaction should be considered as a CUP - the determination of arm's length price as approved by the RBI/SIA is valid
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