Dispute Over Arm's Length Price: Lack of Clarity in Foreign Language Debit Notes Leads to Confusion in Transfer Pricing.

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....TP Adjustment - computing the Arm's Length Price (ALP) - any other method - We fail to understand that how the lower authorities have reached at a conclusion on the 3 Sample debit notes which are in a foreign language. Assessee has also not narrated the facts properly that how the above expenditure cross-charged to the assessee company by its associated enterprises. Even the complete breakup of the expenditure showing the nature of expenditure was also not submitted. - AT....