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Foreign AE cannot be regarded as tested party for ALP determination of transactions between assessee and its AE
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International Tax
Foreign AE cannot be regarded as tested party for ALP determination of transactions between assessee and its AE
Posted on
on
January 31, 2020
Tenet Tax Daily January 31 2020
By
tenettax-team
International Tax
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Additions deleted upon examination of facts in support of credit in bank a/c – ITAT
Loans given by assessee to its AE to be determined on basis of rate of interest being charged in country where loan was received/consumed
