Sections 92C and 92CA of Income Tax Act: Distinct Roles in Transfer Price Adjustments Explained.

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....Reference made to TPO - Transfer Price Adjustments (TPA) – Whether Section 92C and 92CA of the income tax act are independent of each other – the words "the said international transaction under section 92C" do not, lead to the conclusion that the requirement of section 92C(3) can be read into section 92CA(1) of the Act - AT....