Arm's Length Principle: Foreign Enterprise's Tax Gains or Losses Irrelevant; Focus on Functional, Not Product Similarity in Chapter X.

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....Transfer pricing - ALP - Whether said foreign A.E. is having losses, or otherwise not benefitted in any tax savings in that country, is not matter of examination in this Chapter-X of IT Act - it is incorrect to hold that ‘functional similarity' is to be preferred over and above 'product similarity' - AT....