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HC ruled that Transfer Pricing adjustments framework agreed under Mutual Agreement Procedure (MAP) between US and India cannot be applied to non-US transactions. The court emphasized that MAP resolutions are based on consensus between competent authorities of contracting states and cannot be extrapolated to transactions outside its scope. Arm's Length Price for non-US transactions must be determined under Section 92C and Rule 10B. The ITAT's direction to apply US MAP framework to non-US transactions was overturned as it effectively imposed a negotiated settlement where no consensus existed with other countries' tax authorities. The framework's application would improperly foreclose an assessee's right to dispute TP adjustments in materially different situations.
HC ruled that Transfer Pricing adjustments framework agreed under Mutual Agreement Procedure (MAP) between US and India cannot be applied to non-US transactions. The court emphasized that MAP resolutions are based on consensus between competent authorities of contracting states and cannot be extrapolated to transactions outside its scope. Arm's Length Price for non-US transactions must be determined under Section 92C and Rule 10B. The ITAT's direction to apply US MAP framework to non-US transactions was overturned as it effectively imposed a negotiated settlement where no consensus existed with other countries' tax authorities. The framework's application would improperly foreclose an assessee's right to dispute TP adjustments in materially different situations.
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