Business Transfer to Banca Sella S.P.A. Not Subject to Rule 10AB; No Transfer Pricing Adjustments Needed.

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....Transfer pricing adjustments (TPA) - ALP - the assessee has transferred its business operations in India to Banca Sella S.P.A. having its branch in India. - the business transfer are not covered under Rule 10AB. - No upward adjustment can be made - AT....