64 results for “transfer pricing”+ Section 10(20)clear
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In the result, these appeals are dismissed and the substantial
Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE CHAITALI CHATTERJEE (DAS)
10. The CIT(A) found that there was no dispute between the assessee and the TPO regarding the method to be used while bench marking the transfer of power and the controversy has arisen only on account of the difference in the manner of bench marking the transfer price of power under the CUP method. The CIT(A) noted Rule