64 results for “transfer pricing”+ Section 17(1)(iv)clear
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Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE CHAITALI CHATTERJEE (DAS)
iv) that the landed rate at which non-eligible unit purchases power from SEB as comparable rate under arm’s length standards without appreciating the fact that the said rate is regulated and therefore cannot be said to represent an uncontrolled transaction. (v) that considering assessee’s benchmarking taking external CUP as Most appropriate method when the internal