| COURT: | ITAT Pune |
| CORAM: | G. S. Pannu (AM), Sushma Chowla (JM) |
| SECTION(S): | 92CA, Rule 10AB |
| GENRE: | Transfer Pricing |
| CATCH WORDS: | aggregation, international transactions, Transfer Pricing |
| COUNSEL: | Arvind Sonde |
| DATE: | December 31, 2014 (Date of pronouncement) |
| DATE: | January 8, 2015 (Date of publication) |
| AY: | 2005-06 |
| FILE: | Click here to view full post with file download link |
| CITATION: | |
| Transfer Pricing: Closely linked international transactions can be aggregated to determine the ALP | |
On a combined reading of Rule 10A(d) and 10B of the Rules, a number of transactions can be aggregated and construed as a single ‘transaction’ for the purposes of determining the ALP, provided of course that such transactions are ‘closely linked’
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