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Indian Transfer Pricing Rule Requires Current Year Data for Comparability Analysis in International Transactions.

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Full Text of the Document

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....TP - ALP - The use of the word "shall" in the main provision of the Rule makes it abundantly clear that the use of data of the current financial year (i.e. of the financial year in which the international transaction was actually entered into) is a mandatory requirement of law in the comparability analysis to be undertaken as as per Indian T.P. Regulations - AT....