Dispute Panel's Approach Rejected: Arm's Length Price Adjustment Must Apply Equally to Associated Enterprises in International Transactions.

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....TP Adjustment - The Legislature has never shown an intention to treat the same international transaction in two different ways in the hands of two associated enterprises such that there would be arm’s length price adjustment at least in the hands of one of the associated enterprises. Hence, the approach adopted by the DRP/TPO is not acceptable.....