The Tribunal observed that MAP and APA settlements, while not legally binding on different years, hold strong persuasive value in maintaining consistency in TP assessments
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT)set aside an arbitrary transfer pricing adjustment on royalty payments and directed the Transfer Pricing Officer (TPO) to align with the Advance Pricing Agreement (APA) parameters. The assessee, JCB India, is the Indian subsidiary of a multinational company engaged in the manufacturing and trading of construction…
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