Taxpayer's Business Function Mischaracterization: Risks Must Be Proven to Classify as Trader Under Arm's Length Price Rules.

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....Addition on account of difference in Arm’s Length Price - characterization of the business function of the taxpayer - When the taxpayer is not proved to be a risk bearer in the nature of credit risk, price risk, inventory risk, storage and handling risk etc., it cannot be treated as a trader. - AT....