TPO Fails to Justify Exclusion of Expenses; No Transfer Pricing Adjustment Needed for Domestic-Personal Care Division's AE Exports.

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....TP Adjustment - goods sold to Associated Enterprises (AEs) - NP Determination - The TPO has not given any reason as to why he did not consider above said two expenses while working out net profit margin of “Domestic-Personal care division”. - it has to be held that the international transactions of making exports to AEs are at arms length and hence no T.P adjustment is called for. - AT....