Transaction Value in Intra-Associated Enterprise Sales Not Uncontrolled; Original Terms Irrelevant for Arm's Length Price. TPO Approach Flawed.

Transaction Value in Intra-Associated Enterprise Sales Not Uncontrolled; Original Terms Irrelevant for Arm's Length Price. TPO Approach Flawed. https://www.taxtmi.com/highlights?id=41242 In an intra AE situation, the transaction value of sale of shares cannot be said to be an uncontrolled price at all. Nothing, therefore, turns on the original agreement terms and it has no relevance in determination of arm’s length price. The very approach of the TPO is thus vitiated in law. en-us Wed, 05 Sep 2018 09:20:25 +0530 Wed, 05 Sep 2018 09:20:25 +0530 TaxTMI RSS Generator Transaction Value in Intra-Associated Enterprise Sales Not Uncontrolled; Original Terms Irrelevant for Arm's Length Price. TPO Approach Flawed. https://www.taxtmi.com/highlights?id=41242 In an intra AE situation, the transaction value of sale of shares cannot be said to be an uncontrolled price at all. Nothing, therefore, turns on the original agreement terms and it has no relevance in determination of arm’s length price. The very approach of the TPO is thus vitiated in law. Highlights Income Tax Wed, 05 Sep 2018 09:20:25 +0530 https://www.taxtmi.com/highlights?id=41242