Arbitration intelligence VIA Transfer Pricing Hyundai Rotem Company (Appellant) v. ACIT (Respondent) ITA No.510/Del./2016 dated 22/11/2017 FACTS M/s. Hyundai Rotem Company, the taxpayer, paid an amount to DMRC out of the remittance received from the Head office. But, Transfer Pricing Officer (TPO) had the view that Associated Enterprises (AE) reimbursed the taxpayer as a usual…
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