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TP adjustment is to be made only in respect of purchases made from AE and not from unrelated parties

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  • TP adjustment is to be made only in respect of purchases made from AE and not from unrelated parties
Posted onon April 28, 2015

Tenet Tax Daily April 27 2015

By tenettax-team
International Tax

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Timely service of sec. 143(2) notice is mandatory and not only a mere procedural requirement
No agency PE under India-France DTAA even if agent is wholly dependent on foreign Co. unless transaction isn’t at ALP

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