ALP not to be computed if transaction is not with associated enterprise

If an entity is not an “associated enterprise”, there cannot be any computation of income from “international transaction” having regard to ALP

Brief of the Case: In the case of Price Waterhouse & Anr. Vs CIT, Calcutta High Court through an interim order opined that if there was no relevant material in the hands of the Income Tax authorities with which it has come to an incontrovertible conclusion that the writ petitioner no.1 was an ‘associated enterprise’ of Pricewate

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