Assessee Must Prove Holding Company's Role in Business for Transfer Pricing Adjustment and Arm's Length Price Determination.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....TPA - ALP determination - nature of services received by the Assessee - Mere furnishing of details of consignment without evidence of participation of holding company in procuring those business would not be sufficient to discharge the burden that lies with the assessee.....