Primary adjustment: arm's length transfer pricing increases taxable income by aligning related party prices with market benchmarks. Primary Adjustment denotes the determination of a transfer price by applying the arm's length principle to related party transactions, producing an increase in the assessee's total income or a reduction in loss by realigning intercompany prices with independent benchmarks for tax purposes.
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Provisions expressly mentioned in the judgment/order text.
Primary adjustment: arm's length transfer pricing increases taxable income by aligning related party prices with market benchmarks.
Primary Adjustment denotes the determination of a transfer price by applying the arm's length principle to related party transactions, producing an increase in the assessee's total income or a reduction in loss by realigning intercompany prices with independent benchmarks for tax purposes.
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