ALP not to be tested with growth in business rather by applying suitable method to transaction itself

Brief of the case:

• The ITAT Delhi in the above cited case held that as to whether a transaction is entered into at an Arm’s Length Price or not must depend upon the facts of each case relating to the transaction per-se i.e. the transaction itself as the profit is only a possibility of the desired result with or without the aid of international transaction.

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