Transfer Pricing Error: Incorrect Income Imputation Due to Non-Existent Agreement u/s 92(1) of Income Tax Act.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....TP - Reimbursement of expenses / out of pocket expenses - Transfer Pricing Officer erred in proceeding to infer a non-existent understanding between assessee and its associated enterprises so as to impute income qua the instant transaction in terms of section 92(1) - AT....