Transfer Pricing Provisions Inapplicable: ALP Adjustments Could Harm Indian Tax Base, Violating Section 92(3) Intent.

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....TPA - This is a case in which transfer pricing provisions cannot be applied because the application of ALP adjustment will indeed result in erosion of Indian tax base- as visualized by the scheme of Section 92(3) inasmuch for every rupee of ALP adjustment in intra group service, the revenue of the assessee, on the basis of application of arm’s length price, will stand reduced by one and one fifth times of the ALP adjustment. - AT....