Transfer Pricing Adjustments Apply Despite Section 10B Exemption, Must Align with Global Standards and Not Be Solely Tax-Driven.

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....TP adjustment - scope of TP adjustment when assessee is eligible for exemption u/s 10B - Irrespective of profit making ability and exemption available in the country of operation the transfer price of the global market and the corporates must be within the band of pricing - tax saving alone cannot be a decision making process to restrict any TP adjustment....