India-USA Tax Agreement: CBDT Extends Transfer Pricing Terms to Non-US Transactions, Disallowing Revenue's Future Objections.

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....TP adjustment - scope of Mutually Agreed Procedure (MAP) for determining the tax between India & USA - once CBDT in the later year agreed that transfer pricing consideration in relation to US based transactions can be safely adopted for the purpose of the assessee's non-US based transactions then it would be wholly inappropriate to allow the revenue to argue to the contrary....