6 results for “transfer pricing”+ Section 44Dclear
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Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh
transfer pricing regulations. Ground No. 4 That Ld CIT(A) erred in law and on facts by failing to appreciate that the functional profile of the Appellants PE is even below a low risk distributor and that the Appellants PE does not assume title of the goods sold in India and merely provides low end coordination support services