Judicial Consistency Key in Deleting Transfer Pricing Adjustments for Advisory Services in International Transactions.

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Full Text of the Document

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....TP adjustment - Determining the Arm's Length Price of international transactions in respect of "advisory services" - we adopt judicial consistency in the absence of any clinching distinction in both these assessment years involving the very issue of correctness of arm's length price adjustment in respect of advisory services. - TP adjustments deleted - AT....