https://www.taxtmi.com/highlights?id=68679 TP Adjustment - related parties / associated enterprise or not - Re-computation of arm's length price of shares sold by the assessee - Admittedly, in the instant case Relay BV holds controlling stake in USL of more than 26% i.e. 26, 37% on 28.11.2013 i.e. during the relevant previous year. Therefore in light of the clear provisions of Section 92A(2) of the Act, which uses the expression "if at any time during the previous year" we find no merit in the contention of the learned Sr. Counsel. - AT en-us Sat, 11 Mar 2023 08:48:55 +0530 Sat, 11 Mar 2023 08:48:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=68679 TP Adjustment - related parties / associated enterprise or not - Re-computation of arm's length price of shares sold by the assessee - Admittedly, in the instant case Relay BV holds controlling stake in USL of more than 26% i.e. 26, 37% on 28.11.2013 i.e. during the relevant previous year. Therefore in light of the clear provisions of Section 92A(2) of the Act, which uses the expression "if at any time during the previous year" we find no merit in the contention of the learned Sr. Counsel. - AT Highlights Income Tax Sat, 11 Mar 2023 08:48:55 +0530 https://www.taxtmi.com/highlights?id=68679