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