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        Case ID :
        Income Tax

        TP Adjustment - As per the provisions of aforesaid Rule, the...

        Incorrect Valuation in Transfer Pricing: Authorities Failed to Use Comparable Uncontrolled Transactions for IT Support Services.

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                TP Adjustment - As per the provisions of aforesaid Rule, the ‘other method’ shall be the method which takes into account the price which has been or would have been charged or paid for the same or similar uncontrolled transaction between non-associated enterprises. However, in the present case, the lower authorities without searching for similar uncontrolled transaction between non-associated enterprises, straightaway treated the value of the international transaction to be at NIL. - TPO as well as learned DRP were not justified in treating the value of international transaction of ‘Payment of Corporate IT Support Services’ to be NIL - AT
                                Note: It is a system-generated summary and is for quick reference only.
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