Arm's length price requirement governs income and expense treatment in international transactions, including allocation among associated enterprises. Income and allowance for expenditure or interest in international and specified domestic transactions must be computed by the Arm's Length Price; allocations of cost or expense under agreements between associated enterprises must likewise be based on ALP. The ALP rules are inapplicable where their application would reduce income chargeable to tax or increase loss as shown in the books of account.
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Provisions expressly mentioned in the judgment/order text.
Arm's length price requirement governs income and expense treatment in international transactions, including allocation among associated enterprises.
Income and allowance for expenditure or interest in international and specified domestic transactions must be computed by the Arm's Length Price; allocations of cost or expense under agreements between associated enterprises must likewise be based on ALP. The ALP rules are inapplicable where their application would reduce income chargeable to tax or increase loss as shown in the books of account.
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