ALP determinable on combined accounts approach in case of failure to separate common costs

TPO determined ALP on the combined accounts approach rather than the split approach adopted by assessee as assessee failed to substantiate such common material costs were properly allocated segment-wise and Transfer Pricing Adjustment made at entity level should be restricted to international transactions only.

from TaxGuru https://ift.tt/3gAWHhb
via IFTTT

Post a Comment

If You have any doubts,please let me know.

Previous Post Next Post