Indian Branch of Japanese Firm Taxed on Income from HQ Transactions Under Transfer Pricing Rules.

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....Transfer pricing adjustment - transaction between a head office in a foreign country and its branch office in India - principle of mutuality - it is axiomatic that income of the Japanese assessee, as is relatable to the operations carried out in India through its Branch office, is chargeable to tax in India not only under the Act but also under the DTAA. - AT....