Assessee Must Choose Transfer Pricing Method per Act; TPO to Justify Disputes with Comparables; Sample Basis Allowed.

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Full Text of the Document

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....TPA - The assessee has to choose a method in accordance with the Act and the Rules. On production of such evidence, the Transfer Pricing Officer will have to give the basis of his price, if he disputes the assessee's claim with comparable cases - assessee can demonstrate on a sample basis item expenditure comprised in the management fee - AT....