734 results for “transfer pricing”+ Unexplained Moneyclear
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In the result, the recalled matter of the appeal in ITA No
Bench: Shri Amit Shukla & Shri O.P. Kant
money or a written agreement as suggested by the Revenue, and even if resort is had to Section 92F (v) which defines 'transaction' to include 'arrangement', 'understanding' or 'action in concert', 'whether formal or in writing', it is still incumbent on the Revenue to show the existence of an 'understanding' or an 'arrangement' or 'action in concert' between MSIL