Determination of ALP of an international transaction

RELEVANT PARAGRAPH 8. We have heard the rival submissions at length and perused the relevant material on record. The Id. counsel for the assessee contended that the provisions of section 92CA were not applicable in the present case because there was no reduction in the tax liability of the assessee. He stated that it was not a case in which the assessee had endeavored to reduce any income or the incidence of tax. It was pointed out that Dicamba was exported by the assessee to USA and other countries. Direct export to USA was not permissible and in order to overcome this difficulty, the Id. AR ...