Transfer Pricing Adjustments: Use Operating Profit, Not Net Profit, for TNMM Comparisons in International Transactions.

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....TPA - 'operating profit’ from the international transaction is compared with the operating profit margin of the comparables under the TNMM. Thus the addition based on the transfer pricing adjustment, on the strength of `net profit’ as numerator in contrast to `operating profit’, cannot be upheld - AT....