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Disallowed Expenditures Must Be Excluded from Operating Expenses in Arm's Length Price Calculations for Transfer Pricing Adjustments.

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....TP Adjustment - Determination of Arms Length Price (ALP) - Once a particular expenditure itself is disallowed, there can be no question of including it in the Operating expenses for calculating the profit margin in the process of determination of the ALP. - AT....

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Disallowed Expenditures Must Be Excluded from Operating Expenses in Arm's Length Price Calculations for Transfer Pricing Adjustments.