S. 92C : Transfer pricing–Arm’s length price-Mutually agreed procedure (MAP) adopted by Governments of India and USA in relation to US based transactions for determination of ALP could also be adopted for determining ALP of on –US based transactions.
PCIT v. J.P. Morgan Services India (P) Ltd. (2019) 263 Taxman 141/ 182 DTR 373 / 311 CTR 15( Bom) (HC) .