https://www.taxtmi.com/highlights?id=67931 TP Adjustment - arm’s length price (ALP) of the international transaction - The tinkering of PLI by substituting the denominator with total cost is unacceptable considering that the TPO has included the cost of traded goods with unrelated parties in the total cost. Therefore, we do not find any infirmity in the decision of learned DRP in directing the TPO to recompute the ALP by strictly restricting himself to the international transaction with the AEs. - AT en-us Fri, 27 Jan 2023 08:33:30 +0530 Fri, 27 Jan 2023 08:33:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=67931 TP Adjustment - arm’s length price (ALP) of the international transaction - The tinkering of PLI by substituting the denominator with total cost is unacceptable considering that the TPO has included the cost of traded goods with unrelated parties in the total cost. Therefore, we do not find any infirmity in the decision of learned DRP in directing the TPO to recompute the ALP by strictly restricting himself to the international transaction with the AEs. - AT Highlights Income Tax Fri, 27 Jan 2023 08:33:30 +0530 https://www.taxtmi.com/highlights?id=67931