35 results for “transfer pricing”+ Section 251clear
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In the result, the appeal of the assessee is dismissed
Bench: Shri Rama Kanta Panda & Shri Laliet Kumar
Transfer Pricing Officer concluding that the figure of receivables beyond 180 days constitutes an international transaction by itself. With the assessee having already factored in the impact of the receivables on the working capital and thereby on its pricing/profitability vis-a-vis that of its comparables, any further adjustment only on the basis of the outstanding receivables would have distorted