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No ALP adjustment if margin on cost of goods sold to unrelated party was less than net margin on sale to AE

September 19, 2019[2019] 108 taxmann.com 298 (Bangalore - Trib.)

TRANSFER PRICING: Where assessee entered into a transaction of sale of cookies manufactured by it in India to its foreign AE and unrelated parties, margins on cost of goods sold to unrelated parties being less than net margins on sale to AE, transactions with AE was to be regarded as at arm's length

TRANSFER PRICING: Where trademark was owned by assessee, AMP expenses could not be disallowed consequent to determination of ALP because those expenses would be in nature of business expenses of assessee

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