Transaction Value in Intra-Associated Enterprise Sales Not Uncontrolled; Original Terms Irrelevant for Arm's Length Price. TPO Approach Flawed.

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....In an intra AE situation, the transaction value of sale of shares cannot be said to be an uncontrolled price at all. Nothing, therefore, turns on the original agreement terms and it has no relevance in determination of arm’s length price. The very approach of the TPO is thus vitiated in law.....