AE's TNMM Study Shows 4.52% Margin; Within Arm's Length Range, No Transfer Pricing Adjustment Needed Under Safe Harbor Clause.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....TPA - As per TNMM study filed by the appellant, the margin on total cost earned by AE is 4.52% which is less when compared with 5.18% in case of other eleven comparable companies. This is within arm's length. Therefore, otherwise also no transfer pricing adjustment is called for by the safe harbor clause. - AT....