Secondary Adjustment - Section 92CE & Rule 10CB

CA Pratik Bhavsar , Last updated: 01 May 2019 Share Follow on Google News

Transfer pricing provisions seek to ensure that there is fair and equitable allocation of taxable profits amongst the tax jurisdictions. In cases where the underlying transaction is held not to be at arm's length, a primary adjustment is made to align the transfer price with the arm's length price (

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Secondary Adjustment - Section 92CE & Rule 10CB

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