Transfer Pricing Adjustment: Assessee's Costs, Not FOB Value, Used in Profit Level Indicator Calculation.

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....Transfer pricing adjustment - Ex consequenti, the “total cost” being the denominator in the PLI of OP/TC, has to be taken as the cost incurred by the assessee and not the FOB value of goods between third party enterprises sourced through the assessee. In other words, the tested party should be the assessee and not its AE - AT....