Pass-through associated enterprise purchases require no arm's length adjustment where credit notes align prices with the unrelated supplier.

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....Transfer-pricing adjustment on raw-material purchases routed through a pass-through associated enterprise is not warranted where the unrelated foreign supplier directly supplies the goods and credit notes reduce the effective price to that supplier's price. An additional invoiced component used solely for customs-duty valuation does not justify an arm's length price adjustment in those circumstances. Compliance with the direction concerning operating revenue results in no further adjustment. The transfer-pricing adjustment on these purchases was deleted and the appeal allowed.....