https://www.taxtmi.com/highlights?id=65059 TP Adjustment - determination of Arm’s Length Price (ALP) - The products are unique and not comparable to others. The terms and conditions and the economic circumstances under which the Assessee sells extruders parts and elements to AE are materially different from the comparable uncontrolled transactions. We are therefore of the view that the question of adopting the profit margins at the entity level based on the submissions made by the Assessee before the CIT(A) cannot be accepted. - AT en-us Wed, 10 Aug 2022 09:30:38 +0530 Wed, 10 Aug 2022 09:30:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=65059 TP Adjustment - determination of Arm’s Length Price (ALP) - The products are unique and not comparable to others. The terms and conditions and the economic circumstances under which the Assessee sells extruders parts and elements to AE are materially different from the comparable uncontrolled transactions. We are therefore of the view that the question of adopting the profit margins at the entity level based on the submissions made by the Assessee before the CIT(A) cannot be accepted. - AT Highlights Income Tax Wed, 10 Aug 2022 09:30:38 +0530 https://www.taxtmi.com/highlights?id=65059