Transfer Pricing – TPO can rely on ‘contemporaneous’ data even if not available at specified date – ITAT Bangalore

Kodiak Networks (India) Pvt. Ltd. Vs. ACIT (ITAT Bangalore)- As far as the data to be used by the TPO while determining the ALP was concerned, it is observed that it is covered by the provisions of rule 10D sub-rule 4 of the Income-tax Rules. Section 92 C provides that the arm’s length price in rel

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