Ad Hoc Tenure Filters for Transfer Pricing and Section 94B Recomputation Are Unjustified
Ad Hoc Tenure Filters for Transfer Pricing and Section 94B Recomputation Are Unjustified Issue Whether the Transfer Pricing Officer (TPO) can introduce an ad hoc minimum tenure filter of 10 years into an external CUP study without economic justification to alter the arm’s-length interest rate on Non-Convertible Debentures (NCDs). Whether additional disallowance under Section 94B… Read More »