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SECTION 92C OF THE INCOME-TAX ACT, 1961 – TRANSFER PRICING – COMPUTATION OF ARMS LENGTH PRICE

June 17, 2024

Comparability factors – Internal comparable : Size of internal comparable does matter in entity level comparison because scale of operations substantially vary and so does underlying profitability factor, but in a transaction level comparison within same entity, mere difference in size of uncontrolled transactions does not render transaction incomparable – Commissioner of Income-tax (International Taxation) v. Lummus Technology Heat Transfer BV – [2024] 163 taxmann.com 411 (Delhi)

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